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Could you provide a source for your anecdote? I find it hard to believe that the FDIC would look at a mere six loans when their own guidelines [1] call for at l
by MrApathy 11y ago
Could you provide a source for your anecdote? I find it hard to believe that the FDIC would look at a mere six loans when their own guidelines [1] call for at least eight, and that's with a population of a mere ten loans. For a higher level of precision on any decent loan portfolio the sample size will be at least 50.
Furthermore, having dealt with regulators before, there's always an opportunity to provide written responses with requests for data or an appeal process. Not hard for a bank to argue that a sample size of six isn't representative of their overall lending practices.
[1] (Warning: PDF) https://www.fdic.gov/regulations/compliance/manual/11/XI-10.1.pdf https://www.fdic.gov/regulations/compliance/manual/11/XI-10....
- c0achmcguirk 11y agoIt was an anecdote from Bill Goedken at the 2015 CUNA CFO Conference. It was from the session "Mining Gold – New Trends and Discoveries in ‘Big Data’ That Will Help Your Credit Union Compete". I've linked to the slides ([1]) but there was no mention of the anecdote in them. [1] - http://www.cunacouncils.org/cuna/assets/files/144820_Goedken_cfo2015.pdf http://www.cunacouncils.org/cuna/assets/files/144820_Goedken...