Financial Institution Letter
FIL-49-2018
September 17, 2018
Interagency Statement Clarifying the Role of Supervisory
Guidance
Summary: The FDIC, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of
the Currency, the Bureau of Consumer Financial Protection, and the National Credit Union Administration (the
agencies) jointly have issued a statement to explain the role of supervisory guidance and to describe the
agencies’ approach to supervisory guidance.
Statement of Applicability to Institutions with Total Assets under $1 Billion: This Financial Institution Letter
applies to all FDIC-supervised financial institutions.
Suggested Distribution:
FDIC-Supervised Institutions
Highlights:
The purpose of supervisory guidance is to articulate the
agencies’ general views regarding appropriate practices for a
given subject area.
The agencies issue various types of supervisory guidance to their
respective supervised institutions, including; interagency
statements, advisories, bulletins, policy statements, questions
and answers, and frequently asked questions.
A statute or regulation has the force and effect of law. Unlike a
statute or regulation, supervisory guidance does not have the
force and effect of law, and the agencies do not take
enforcement actions based on supervisory guidance.
Supervised institutions at times request supervisory guidance,
and such guidance is important to provide insight to the industry,
as well as supervisory staff, in a transparent way that helps to
ensure consistency in the supervisory approach.
Agencies intend to limit the use of numerical thresholds in
describing expectations in supervisory guidance, and clarify that
they are exemplary only and not suggestive of requirements.
Agencies will not criticize institutions for a “violation” of
supervisory guidance.
Agencies may continue to seek public comment on supervisory
guidance to gather information, improve understanding of issues,
or seek ways to achieve supervisory objectives most effectively
and with least burden on institutions.
Agencies will seek to reduce the issuance of multiple guidance
documents on the same topic.
Agencies will continue efforts to be clear in communications
regarding guidance and to encourage questions from supervised
institutions.
Suggested Routing:
Board of Directors
Chief Executive Officer
Compliance Officer
Attachment:
Interagency Statement on the Role of Supervisory
Guidance
Contact:
Thomas Lyons, Section Chief, at (202) 898-6850 or
by email tlyons@fdic.gov.
Paul Robin, Section Chief, at (202) 898-6818 or by
email probin@fdic.gov.
Note:
FDIC Financial Institution Letters (FILs) may be
accessed from the FDIC's website at
www.fdic.gov/news/news/financial/2018/
To receive FILs electronically, please visit
www.fdic.gov/about/subscriptions/fil.html.
Paper copies may be obtained through the FDIC's
Public Information Center, 3501 Fairfax Drive, E-
1002, Arlington, VA 22226 (877-275-3342 or 703-
562-2200).
Federal Deposit Insurance Corporation
550 17th Street NW, Washington, D.C. 20429-9990
FIL-49-2018
September 17, 2018
Interagency Statement Clarifying the Role of Supervisory
Guidance
Summary: The FDIC, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of
the Currency, the Bureau of Consumer Financial Protection, and the National Credit Union Administration (the
agencies) jointly have issued a statement to explain the role of supervisory guidance and to describe the
agencies’ approach to supervisory guidance.
Statement of Applicability to Institutions with Total Assets under $1 Billion: This Financial Institution Letter
applies to all FDIC-supervised financial institutions.
Suggested Distribution:
FDIC-Supervised Institutions
Highlights:
The purpose of supervisory guidance is to articulate the
agencies’ general views regarding appropriate practices for a
given subject area.
The agencies issue various types of supervisory guidance to their
respective supervised institutions, including; interagency
statements, advisories, bulletins, policy statements, questions
and answers, and frequently asked questions.
A statute or regulation has the force and effect of law. Unlike a
statute or regulation, supervisory guidance does not have the
force and effect of law, and the agencies do not take
enforcement actions based on supervisory guidance.
Supervised institutions at times request supervisory guidance,
and such guidance is important to provide insight to the industry,
as well as supervisory staff, in a transparent way that helps to
ensure consistency in the supervisory approach.
Agencies intend to limit the use of numerical thresholds in
describing expectations in supervisory guidance, and clarify that
they are exemplary only and not suggestive of requirements.
Agencies will not criticize institutions for a “violation” of
supervisory guidance.
Agencies may continue to seek public comment on supervisory
guidance to gather information, improve understanding of issues,
or seek ways to achieve supervisory objectives most effectively
and with least burden on institutions.
Agencies will seek to reduce the issuance of multiple guidance
documents on the same topic.
Agencies will continue efforts to be clear in communications
regarding guidance and to encourage questions from supervised
institutions.
Suggested Routing:
Board of Directors
Chief Executive Officer
Compliance Officer
Attachment:
Interagency Statement on the Role of Supervisory
Guidance
Contact:
Thomas Lyons, Section Chief, at (202) 898-6850 or
by email tlyons@fdic.gov.
Paul Robin, Section Chief, at (202) 898-6818 or by
email probin@fdic.gov.
Note:
FDIC Financial Institution Letters (FILs) may be
accessed from the FDIC's website at
www.fdic.gov/news/news/financial/2018/
To receive FILs electronically, please visit
www.fdic.gov/about/subscriptions/fil.html.
Paper copies may be obtained through the FDIC's
Public Information Center, 3501 Fairfax Drive, E-
1002, Arlington, VA 22226 (877-275-3342 or 703-
562-2200).
Federal Deposit Insurance Corporation
550 17th Street NW, Washington, D.C. 20429-9990