Compliance Guide · 2026 · 02 · 8 min read

FDIC Examination Preparation: A 90-Day Checklist

The banks that come through examinations cleanly are rarely the ones with the most sophisticated compliance programs. They are the ones that prepared deliberately in the ninety days before the examiners arrived. This checklist organizes that window.

Days 90–60: scope and self-assessment

Start from your last Report of Examination. Every prior finding, MRA, and recommendation is a guaranteed topic; assemble the evidence that each was remediated and that the fix held. Review the pre-examination request list from your last cycle — the next one will look similar — and identify which documents will take longest to produce. Confirm board and committee minutes are complete and signed, because gaps in governance records are among the easiest findings an examiner will ever write.

This is also the window for a policy-level gap analysis: compare your deposit agreements, lending policies, BSA/AML program, vendor management framework, and privacy notices against current requirements. Sixty days is enough time to revise a policy and route it through committee approval; ten days is not.

Days 60–30: fix what you found

Prioritize remediation by examination consequence. Public-facing documents — deposit agreements, privacy notices, fee schedules — come first, both because examiners can read them before arriving and because customer-facing inaccuracy carries the sharpest consequences. Update policies through your real approval process; a policy revised the week before an exam without committee approval creates a governance finding on top of the original gap. Where remediation cannot complete before the exam, document the plan, the owner, and the date — examiners respond far better to a candid in-progress plan than to a discovered gap.

Days 30–0: rehearse

Run mock file pulls: select loan files, new-account files, and SAR/CTR support the way an examiner would — by sampling, not by choosing your best work — and review them against your own policies. Brief every employee likely to be interviewed on the ground rules: answer what is asked, accurately and briefly; never guess; and if you don't know, say who does. Assign a single examination coordinator who controls document flow, logs every request and delivery, and keeps management informed daily.

Exam week

Deliver requested items promptly and completely — slow or partial production reads as either disorganization or evasion, and both are worse than most findings. Take every opportunity for status meetings with the examiner-in-charge; surprises at the exit meeting mean communication failed during the exam. When examiners preview likely findings, do not argue in the moment: gather the facts, and if you have genuine contrary evidence, present it calmly before the exit.

After the exam

Treat the Report of Examination as next cycle's opening scope. Every finding gets an owner, a date, and a validation step, tracked at the committee level until closed — the discipline described in our MRA response guide. Banks that close findings once and permanently are the banks whose examinations get shorter over time.