“Twas the night before the
examination and all through the bank,
We awaited the examiners, our spirits were dank..
The Policies were bound in a book with great care,
We all gathered around to say a quick prayer.
The bank staff so jittery just thinking of the Feds,
While visions of violations danced
through their heads.
How could this go right with so much at stake?
Our capital so vulnerable was there for the take.
When out in the lobby there arose such a clatter;
We sprang from our desks to see
what was the matter.
And what to our unlucky eyes should appear,
But a man with a badge and eight of his peers.
With computers and briefcases and faces so numb,
We knew in a flash that our time had just come.
More rapid than soldiers he filed in his clan,
And he gathered them all in an office to plan.
“Be picky, be thorough, be tough, use your weight,
To let them all know you have control of their fate.
To Credit, to Audit, go make them feel small,
Now dash away, dash away, dash away all.”
And then in a twinkling we heard through the door,
The sharpening of dozens
of claws on the floor;
And as the door opened,
our eyes grew quite large,
Out came the head honcho,
He was dressed up like Rambo,
from his head to his feet,
He looked like he craved a good
piece of raw meat.
A bundle of printouts he held close to his chest,
For two long weeks the copier, it would not rest.
His eyes did not twinkle, his brow did not bend.
Is there anyone out there this man could call friend?
He was calm and collected, so passive and cold,
He backed down to no one but God we are told.
The stub of a pencil he held tight in his teeth,
From his belt hung “APR Examiner”
tucked in a sheath.
First to the break room to fill up his large belly,
Free coffee and soft drinks and donuts with jelly.
He’d work for an hour and
then break for some lunch,
Where he went for two hours,
we don’t have a hunch.
For the rest of the day he would talk on the phone,
And tie up the line ‘til the time to go home.
This routine dragged; would he never be done?
Finally his troops had all gone, ev’ry last one.
And then the day came when he said we should meet.
We entered “his” office; he said “take a seat.”
“Regs have all changed, your policy stinks,
Our file samples should be doubled methinks.
Looking at HMDA, it’s not your best year,
You need creative underwriting, it’s all crystal clear.
Your Reg. DD schedule is wrong,
you must cut your fees,
What do you mean who it TILA,
rethink your compliance strategies.
But what we won’t stand for is legal infractions,
If you don’t add controls, we could take further actions.
“Now don’t feel badly, such problems aren’t rare,
But I still feel impelled to give you a good scare.”
He spoke no more words,
but walked straight out the door,
We followed him wondering
if he would be telling us more.
He shook his finger at us from afar,
And nodding his head he got into his car.
And we heard him exclaim with very much cheer,
“You passed your exam, I’ll see you next year!”
Merry Christmas and Happy New Year to our Kansas community banking family!