OFFICE OF 

INSPECTOR GENERAL

Farm Credit Administration's 

Office of Examination Structure 

and Organization 

Benchmarking Evaluation 

E-18-02

Evaluation Report

Evaluator

Sonya Cerne

March 20, 2019

FARM CREDIT ADMINISTRATION
Farm Credit Administration Office of Inspector General

1501 Farm Credit Drive

McLean, Virginia 22102-5090

March 20, 2019

The Honorable Dallas P. Tonsager, Board Chairman 

The Honorable Jeffery S. Hall, Board Member

The Honorable Glen R. Smith, Board Member 

Farm Credit Administration

1501 Farm Credit Drive

McLean, Virginia 22102-5090

Dear Chairman Tonsager and Board Members Hall and Smith:

The Office of Inspector General (OIG) completed a Benchmarking Evaluation on the Farm Credit 

Administration’s (FCA) Office of Examination (OE) Structure and Organization. The objective of 

this evaluation was to compare FCA’s examiner career structure and organization within the OE 

to other federal financial regulators. This report does not contain any recommendations; however, 

we included considerations for FCA regarding examination staff.

To accomplish the benchmarking study, we conducted a survey with several federal financial 

regulators (the Federal Housing Finance Agency was issued a survey but elected not to 

participate):

• Consumer Financial Protection Bureau

• Federal Deposit Insurance Corporation

• Board of Governors of the Federal Reserve System

• National Credit Union Administration

• Office of the Comptroller of the Currency

• U.S. Securities and Exchange Commission

FCA is the smallest of the benchmarked agencies in size and in the number of institutions it 

examines. The benchmarking study found that the agencies surveyed varied in size, location, and 

organizational structure. Notwithstanding the differences, we found similar supervisor ratios and 

that most agencies surveyed were not using resident examiners. Each agency had unique 

responses on the location of examination staff and whether examiners were located in the same 

duty stations as their supervisors. 
We appreciate the courtesies and professionalism extended by FCA personnel to the OIG staff. If 

you have any questions about this evaluation, Sonya Cerne and I would be pleased to meet with 

you at your convenience.

Respectfully,

Wendy R. Laguarda

Inspector General

Enclosure
OBJECTIVE: 

The objective of this evaluation was to 

compare FCA’s examiner career structure

and organization within the OE to other 

federal financial regulators.

RECOMMENDATIONS:

This report contains no recommendations.

SURVEY QUESTIONS:

1. How many Full-Time Equivalents are in

your Agency who perform examination

duties? Please include all examination

staff in this number.

2. Please list the number of examiners in

each of your agency’s field office and

headquarters locations.

3. Please explain how your agency locates

examination staff (that is, whether staff

are located geographically based on

the financial institutions they examine,

by specialty area, or other factor).

4. How many Full-Time Equivalents did

your agency hire for examination duties

in FY 2017?

5. What is the ratio of supervisors to

examiners in your agency?

6. How many institutions does your

agency examine each year?

7. Are examiners located in the same duty

station as their supervisors?

8. Do you have any resident examiners

(where the examiners reside on-site

with the entity they review)? If so, how

many?

9. Please provide any other information

you think would be helpful to the Farm

Credit Administration or that impacts

any of your answers to the above

questions (telework, flexiplace,

statutory requirements).

The Farm Credit Administration (FCA or Agency) is an 

independent Federal agency responsible for regulating, 

examining, and supervising the Farm Credit System (System) and

the Federal Agricultural Mortgage Corporation (Farmer Mac). The 

mission of the Agency is to ensure a safe, sound, and dependable 

source of credit and related services for all creditworthy and 

eligible persons in agriculture and rural America.

FCA’s Office of Examination (OE) is responsible for examining and 

supervising the System in accordance with the Farm Credit Act of 

1971, as amended (Act), and applicable regulations. Under the 

Act, OE must examine each institution no less than once each 18-

month period and Federal land bank associations at least once 

every three years. Overall, FCA has about 300 employees, with 

about half of the employees dedicated as examiners. 

To accomplish the benchmarking study, we conducted a survey

with several federal financial regulators (the Federal Housing 

Finance Agency was issued a survey but elected not to 

participate): 

• Consumer Financial Protection Bureau

• Federal Deposit Insurance Corporation

• Board of Governors of the Federal Reserve System

• National Credit Union Administration

• Office of the Comptroller of the Currency

• U.S. Securities and Exchange Commission

The benchmarking study found that the agencies surveyed varied 

in size, location, and organizational structure. FCA is the smallest 

of the benchmarked agencies in size and in the number of 

institutions it examines. Notwithstanding the differences, we 

found several similarities regarding supervisory ratios and not 

using resident examiners. Each agency had unique responses on 

the location of examination staff and whether examiners were 

located in the same duty stations as their supervisors. 

Executive Summary

E-18-02
TABLE OF CONTENTS

ACRONYMS ______________________________________________________________________________________ 1

BACKGROUND ___________________________________________________________________________________ 1

Examination Staff at FCA ________________________________________________________________________ 2 

Comparison to Other Federal Financial Regulators _____________________________________________ 6 

SURVEY RESULTS ________________________________________________________________________________ 7

Question 1_______________________________________________________________________________________ 8 

Question 2_______________________________________________________________________________________ 9 

Question 3_____________________________________________________________________________________ 12

Question 4_____________________________________________________________________________________ 13

Question 5_____________________________________________________________________________________ 14

Question 6_____________________________________________________________________________________ 15

Question 7_____________________________________________________________________________________ 17

Question 8_____________________________________________________________________________________ 18

Question 9_____________________________________________________________________________________ 19

Considerations for FCA ________________________________________________________________________ 19

APPENDIX A: OBJECTIVE, SCOPE, AND METHODOLOGY ____________________________________ 20

APPENDIX B: OFFICE AND EMPLOYEE NUMBERS REPORTED BY AGENCIES _______________ 21
1 

ACRONYMS

AED Association Examination Division

BED Bank Examination Division

CFPB Consumer Financial Protection Bureau

EPD Examination Policy Division

Farmer Mac Federal Agricultural Mortgage Corporation

FCA Farm Credit Administration

FCS Farm Credit System

FDIC Federal Deposit Insurance Corporation

FFR Federal Financial Regulator

FHFA Federal Housing Finance Agency 

FRB Board of Governors of the Federal Reserve System

FTE Full-Time Equivalent

FY Fiscal Year

NCUA National Credit Union Administration

OCC Office of the Comptroller of the Currency

OE Office of Examination

RSD Risk Supervision Division

SEC U.S. Securities and Exchange Commission

SDD Staff Development Division

BACKGROUND

The Farm Credit Administration (FCA) is an independent federal agency responsible for regulating 

and examining the Farm Credit System (System) and the Federal Agricultural Mortgage 

Corporation (Farmer Mac), the nation’s two government-sponsored enterprises serving 

agriculture and rural America. The mission of FCA is to ensure that System institutions are safe, 
2 

sound, and dependable sources of credit and related services for all creditworthy and eligible

persons in agriculture and rural America. 

FCA’s Office of Examination (OE) is responsible for examining and supervising the System in 

accordance with the Farm Credit Act and applicable regulations. OE develops oversight plans; 

conducts examinations; monitors the System’s condition and current and emerging risks to the 

System; and develops supervisory strategies to ensure that the System operates in a safe and 

sound manner, complies with the law and regulations, and fulfills its public policy purpose. OE 

must examine each institution no less than each 18-month period and Federal land bank 

associations at least once every three years. Overall, FCA has about 300 employees, with about 

half of the employees dedicated as examiners. 

EXAMINATION STAFF AT FCA

Based on data provided from the Office of Agency Services, FCA’s examination staff totaled 163 

as of May 2018, which included three interns. Of the 163 staff members, 91 are commissioned 

examiners. Examiners are generally placed in one of five divisions within OE: the Risk Supervision 

Division (RSD), Examination Policy Division (EPD), Staff Development Division (SDD), Association 

Examination Division (AED), and Bank Examination Division (BED).1

Individuals are also placed in 

the Office of the Chief Examiner (OCE). AED is the largest division, with about half of the 

examination staff. The following shows the number of examination staff in each division:

1 FCA may also have examiners in other offices, such as the Office of Regulatory Policy.

0 10 20 30 40 50 60 70 80 90

AED

BED

EPD

OCE

RSD

SDD

AED BED EPD OCE RSD SDD

Total 81 32 7 3 3 37

Number of Examination Staff in Each Division
3 

Examination staff at FCA range from VH-32 to VH-44 grade levels. About a quarter of the 

examination staff (40) are at the VH-40 grade level and an additional 37 at the VH-39 grade level, 

which is about 23 percent of the total examination staff. About 87 percent of examination staff 

are in the VH-35 through VH-40 grade levels. The following chart shows the various grade levels 

for the 163 identified examination staff (VH 32-44): 

OE has five field offices located in McLean, VA; Bloomington, MN; Dallas, TX; Denver, CO; and 

Sacramento, CA. The Denver Field Office has the most examination staff, followed by the McLean 

Field Office. The Bloomington and Dallas Field Offices have similar staffing to McLean with 32 and 

31 staff assigned. The Sacramento Field Office has the smallest amount of examination staff. There 

are also seven individuals (about four percent of the total examination staff) that are not located 

in a field office and have permanent flexiplace agreements (identified as other in the chart below). 

The following chart shows how many examination staff are in each duty location:

3 4

22

29

13

37

40

9

4 1 1

Number of Examination Staff in each Grade

32

34

35

37

38

39

40

41

42

43

44
4 

32

31

43

34

16

7

0

5

10

15

20

25

30

35

40

45

50

Bloomington, MN Dallas, TX Denver, CO McLean, VA Sacramento, CA Other

Examination Staff by Duty Location

For supervisory purposes, OE has 18 supervisory examiners and one supervisory program 

manager (VH-40 and VH-41 grade levels). OE also has four Division Directors (VH-42 grade level), 

one Deputy Director (VH-43 grade level), and the Chief Examiner (VH-44 grade level). According 

to the Chief Examiner, examiners are not always located in the same duty stations as their 

supervisors. Placement of examiners can vary in OE based on specialty, division, supervision, 

training, and other needs of OE. Of the 163 examination staff identified, 92 (about 56 percent) are 

located in the same duty station as their supervisor and 71 are in different locations. 
5 

44% not located 

with supervisor

56% located 

with supervisor

Examination Staff and Supervisor Locations

22

59

28

4

6

1

1

2

3

11

26

0 10 20 30 40 50 60 70

without supervisor

with supervisor

without supervisor

with supervisor

without supervisor

with supervisor

without supervisor

with supervisor

without supervisor

without supervisor

with supervisor

AED BED EPD OCE RSD SDD

AED BED EPD OCE RSD SDD

without

supervisor

with

supervisor

without

supervisor

with

supervisor

without

supervisor

with

supervisor

without

supervisor

with

supervisor

without

supervisor

without

supervisor

with

supervisor

Total 22 59 28 4 6 1 1 2 3 11 26

Total of Staff Located in Same Location With or Without 

Supervisors
6 

COMPARISON TO OTHER FEDERAL FINANCIAL REGULATORS

The objective of this evaluation was to compare FCA’s examiner career structure and organization 

within the OE to other federal financial regulators (FFRs).

2

To accomplish the benchmarking study, 

we conducted a survey with the following FFRs, with the assistance of the various Offices of 

Inspector General (the Federal Housing Finance Agency (FHFA) was issued a survey but elected

not to participate):3

• Consumer Financial Protection Bureau (CFPB): CFPB is an independent bureau within the

Federal Reserve System with a mission to regulate the offering and provision of consumer

financial products or services under the federal consumer financial laws and educate and

empower consumers to make better informed financial decisions. CFPB has supervisory

authority over banks, thrifts, and credit unions with assets over $10 billion, as well as their

affiliates. As of March 2018, there were 164 of these entities under CFPB supervision. In

addition, CFPB has supervisory authority over nonbank mortgage originators and servicers;

payday lenders; private student lenders of all sizes; and over larger participants in the

consumer reporting, debt collection, student loan servicing, remittance, and automobile

financing markets.

• Federal Deposit Insurance Corporation (FDIC): FDIC is an independent agency that

supervises insured state-chartered banks that are not members of the Federal Reserve

System, as well as insured state savings associations and insured state chartered branches

of foreign banks; insures the deposits of all banks and thrifts that are approved for federal

deposit insurance; resolves all failed insured banks and thrifts; and may be appointed to

resolve large bank holding companies and nonbank financial companies that are

supervised by the Federal Reserve. The FDIC also has backup supervisory responsibility for

all federally insured depository institutions. As of December 31, 2018, the FDIC was the

primary federal regulator for 3,496 financial institutions.

• Board of Governors of the Federal Reserve System (FRB): FRB is the governing body of the

Federal Reserve System. FRB operates as an independent agency with a mission to foster

the stability, integrity, and efficiency of the nation’s monetary, financial, and payment

systems in pursuit of optimal macroeconomic performance. FRB is the federal supervisor

and regulator of all U.S. bank holding companies, including financial holding companies,

savings and loan holding companies, and state-chartered commercial banks that are

2 We gathered information on details such as supervisory ratio and location and quantity of staff. We did 

not cover career paths or examiner qualifications with FCA or the other surveyed agencies. 

3 The judgmentally selected agencies consisted of federal financial regulators and therefore have similar 

missions, supervisory and examination authorities, and status as independent agencies (the CFPB is an 

independent bureau within the Federal Reserve System).
7 

members of the Federal Reserve System.

4 At the end of 2017, there were a total of 5,380 

state member banks, top tier bank holding companies, and financial holding companies. 

• National Credit Union Administration (NCUA): NCUA operates as an independent agency

with a mission to provide, through regulation and supervision, a safe and sound credit

union system, which promotes confidence in the national system of cooperative credit.

NCUA’s examination program focuses on risks to the credit union system and the National

Credit Union Share Insurance Fund. NCUA has responsibility for about 5,800 credit unions.

• Office of the Comptroller of the Currency (OCC): OCC is an independent bureau of the U.S.

Department of Treasury, with a mission to ensure that national banks and federal savings

associations operate in a safe and sound manner, provide fair access to financial services,

treat customers fairly, and comply with applicable laws and regulations. As of September

2017, OCC had responsibility for about 1,450 banks, federal savings associations, federal

branches, and technology service providers.

• U.S. Securities and Exchange Commission (SEC): SEC operates as an independent agency

with a mission to protect investors; maintain fair, orderly, and efficient markets; and

facilitate capital formation. SEC conducts examinations of registered entities to promote

compliance and monitor risks to retail investors. SEC is responsible for over 30,000

registrants.

SURVEY RESULTS

We issued a survey to each of the selected FFRs asking for the following information:

1. How many Full-Time Equivalents are in your agency who perform examination duties?

Please include all examination staff in this number.

2. Please list the number of examiners in each of your agency’s field office and headquarters

locations.

3. Please explain how your agency locates examination staff (that is, whether staff are located

geographically based on the financial institutions they examine, by specialty area, or other

factor).

4. How many Full-Time Equivalents did your agency hire for examination duties in FY 2017?

5. What is the ratio of supervisors to examiners in your agency?

4 FRB has authority over a variety of other financial institutions and activities such as operations of all Edge 

Act and agreement corporations, the international operations of state member banks and U.S. bank holding 

companies, and the U.S. operations of foreign banking operations. FRB also has assigned responsibilities 

for nonbank financial firms and financial market utilities designated by the Financial Stability Oversight 

Council as systemically important. 
8 

6. How many institutions does your agency examine each year?

7. Are examiners located in the same duty station as their supervisors?

8. Do you have any resident examiners (where the examiners reside on-site with the entity

they review)? If so, how many?

9. Please provide any other information you think would be helpful to the Farm Credit

Administration or that impacts any of your answers to the above questions (telework,

flexiplace, statutory requirements).

We received responses from all the FFRs surveyed except FHFA, which elected not to participate.

Each benchmarked agency answered questions without further guidance from FCA Office of 

Inspector General and without our office independently verifying the information provided. 

The benchmarking study found that the surveyed agencies varied in size, locations, and career

structure and organization. Notwithstanding the differences, we found that several agencies had 

the same or similar examiner to supervisory ratios, made no use of resident examiners and, with 

limited exception, located examiners in the same duty station as their supervisors. The greatest 

dissimilarities among the benchmarked agencies pertained to career structure and organization 

of their examination staff. Of note, the examination staff at two of the smaller agencies, the NCUA 

and CFPB, work remotely full-time. 

QUESTION 1 

How many Full-Time Equivalents (FTEs) are in your Agency who perform examination 

duties? Please include all examination staff in this number. 

Four of the agencies, CFPB, FDIC, FRB and SEC, responded to this question with actual head count 

numbers rather than FTEs. Each agency interpreted for themselves what constituted the 

performance of examination duties. Hence, SEC included administrative, supervisory, and 

analytical personnel in addition to examination staff. FDIC included specialists and assistants in 

addition to its examination staff. FCA numbers are FTEs and include examiners, analysts, interns, 

and supervisory staff.

According to the responses, OCC has the highest number of examination staff with 2,390; followed 

by FDIC with 2,017; FRB with 1,918; SEC with 1,010; NCUA with 666; CFPB with 317; and FCA with 

163.
9 

163

666

1918

317

1010

2390

2017

NCUA FRB CFPB SEC OCC FDIC

Full-Time Equivalents (FTEs) or Headcount of 

Examination Staff

FCA

QUESTION 2

Please list the number of examiners in each of your agency’s field office and headquarters 

locations.

Agencies in our benchmarking study had vastly different staff setups in field office and 

headquarters locations.

5 Some agencies provided very specific information and others, such as

the SEC, reported only high level information. 

• FCA reported examination staff at four field offices and at headquarters in McLean, VA (the

McLean field office is included in the headquarters numbers).

• NCUA reported five regional offices with a smaller group assigned to the central office.6

5 See additional detail in Appendix B for locations reported by agencies.

6 NCUA clarified that all examiners and supervisors work 100 percent of their time remotely. They spend 

their time either at an assigned credit union during an examination or from their homes when they are not 

in travel status.
10

• FRB reported staff located among 30 offices aligned with the 12 Federal Reserve Bank

locations.

• CFPB reported staff in four regional offices across the country.

7

• FDIC reported 86 field office locations over six regions across the U.S. as of May 2018. All

examiners are assigned to the 86 field offices, with the exception of three examiners who

report to two of the six regional offices as their respective duty locations.

• SEC reported 12 offices throughout the U.S. with the largest offices in New York, D.C., and

Chicago, each having about 110-280 employees.

• OCC reported staff at 67 locations between Midsize and Community Bank Supervision,

Large Bank Supervision, and Headquarters.

The following table shows the listing of offices/regions and number of employees by agency: 

Agency Offices/Regions and Number of Employees

FCA Headquarters: 34

Bloomington: 32 

Denver: 43 

Dallas: 31

Sacramento: 16

Other: 7 

TOTAL: 163

NCUA Region 1: 115 examiners, 12 supervisory examiners 

Region 2: 119 examiners, 13 supervisory examiners 

Region 3: 113 examiners, 11 supervisory examiners 

Region 4: 115.2 examiners, 12 supervisory examiners 

Region 5: 116 examiners, 12 supervisory examiners 

Office of National Examination and Supervision (Headquarters): 25 examiners, 3 

supervisory examiners 

TOTAL: 666.2

FRB Federal Reserve Bank of Boston: 114

Federal Reserve Bank of New York: 454

7CFPB clarified that staff are provided support for a home office and work from home or from the 

examination site. Staff do not have a designated office, but they are allowed to use hoteling space at a 

regional office or headquarters when assigned to work in those locations.
11

Federal Reserve Bank of Philadelphia: 49

Federal Reserve Bank of Cleveland: 150

Federal Reserve Bank of Richmond: 165

Federal Reserve Bank of Atlanta: 213

Federal Reserve Bank of Chicago: 236

Federal Reserve Bank of St. Louis: 105

Federal Reserve Bank of Minneapolis: 74

Federal Reserve Bank of Kansas City: 112

Federal Reserve Bank of Dallas: 95

Federal Reserve Bank of San Francisco: 151

TOTAL: 1,918

CFPB Northeast: 80

Midwest: 75

Southeast: 85

West: 77

TOTAL: 317

SEC Varies by 12 offices. New York, D.C., and Chicago are the largest offices with 

approximately 110-280 staff each. The remaining offices generally range between 

30-70 staff.

TOTAL: 1,010

OCC Midsize and Community Bank Supervision: 1,582

Large Bank Supervision: 703

Headquarters: 105

TOTAL: 2,390

FDIC Atlanta Region: 321.6

Chicago Region: 331.8

Dallas Region: 350

Kansas City Region: 328.2

New York Region: 384.9

San Francisco Region: 300.8

TOTAL: 2,017.3
12

QUESTION 3

Please explain how your agency locates examination staff (that is, whether staff are located 

geographically based on the financial institutions they examine, by specialty area, or other 

factor).

As noted earlier, this survey question revealed the greatest discrepancies among the 

benchmarked agencies. Only two of the benchmarked agencies, FRB and the FDIC, generally place 

examiners in the same geographic area of the financial institutions examined. The vast majority of 

NCUA examiners are also placed in the same geographic area as the institutions examined. The

other surveyed agencies and FCA used a combination of factors, such as office needs, specialty 

areas, and supervisory and training needs. 

• At FCA, examination staff are assigned to locations based on needs of the office and, at

times, specialties. When placing examiners, FCA also emphasizes adequate supervision

and interaction during training phases.

• NCUA: “District examination staff (approximately 80% of the examinations staff) are hired

by geographical need and are generally located geographically based on the location of

financial institutions they examine. Specialist examiners (approximately 20% of the

examination staff) are promoted or hired based on specialty area and or need. Specialist

examiners are assigned to specific regions, and therefore serve a specific geography,

though it is much larger than a district. Specialists are, in times of need, temporarily

assigned to other regions and geographical locations based on the needs of the agency

for specific work assignments, examinations and supervision contacts.”

• FRB: “Generally, examination staff are located geographically based on the financial

institutions they examine. There are some exceptions for specialized needs and there is

resource sharing between locations.”

• CFPB: “The CFPB examination staff is organized into four regions: the Northeast,

headquartered in New York City; the Midwest, headquartered in Chicago; the West,

headquartered in San Francisco; and the Southeast, which will be moving from

Washington, DC to Atlanta in 2019. Our examination staff is home duty-stationed,

meaning that they work from home when they are not assigned to be onsite at an

institution. No examiners are duty-stationed at the regional headquarters offices; regional

headquarters staff are limited to a small group of administrative personnel, regional

analysts, and regional management.”

• SEC: “We consider a number of factors but primarily location of [SEC] registrant population,

the particular needs of an office due to recent turnover, and the productivity of each

office.”
13

• OCC:

o “Community Banks – examiners are assigned to a supervisory office (i.e., field office

or satellite office). Examiners are expected to be located within 50 miles of their

assigned field office. Each office has a portfolio and the assigned examiners are

responsible for supervising those institutions. The geography of the portfolio is not

solely determined by distance from the field office. More densely populated areas

have banks that are closer to the supervisory office, while other offices may

supervise institutions further away (i.e., contiguous states). Some portfolios are

comprised of only one type of institution like national trust banks or Regional

Technology Service Providers. Those institutions may be supervised from a central

office regardless of location or proximity to the supervisory field office. The

examiners may or may not be located within their assigned field office.”

o “Midsize Banks – for institutions with resident staff, examiners are located in the

same city as the institution. Examiners-in-Charge may or may not be located in the

same city as the institution. Approximately half of the midsize examiners are

located in Chicago, IL or Washington, DC. The remaining examiners are located in

field and satellite offices (usually location of last position) and commute to an

assigned bank location. We also have subject matter experts, or lead experts, that

assess risks across offices or institutions within a district or Midsize Bank

Supervision. District lead experts are required to be located in an office within their

assigned district. Lead experts for midsize bank supervision are not restricted to a

specific location. However, they must be located in a city that allows for efficient

and cost effective travel.”

o “Large Banks – Most Large Bank Supervision examination staff is geographically

located based on the financial institutions they supervise. Large Bank Supervision

has examination staff (Lead Expert Program) that provide a horizontal perspective

and support that can be located in any Large Bank Supervision city.”

• FDIC: “Risk Management Supervision field examiners are located geographically based on

the financial institutions they examine. Large financial institution specialists are located

around the country and travel to examinations around the country. Depositor and

Consumer Protection examiners are placed in the geographical locations nearest the

institutions they will examine.”

QUESTION 4

How many Full-Time Equivalents (FTEs) did your agency hire for examination duties in FY 

2017?

Responses to this survey question varied among the benchmarked agencies, as noted in the

following chart:
14

Agency Response

FCA 8 FCA hired 13 examiners, including seven interns.

NCUA 2017 included an extended hiring freeze, with essentially no hires for 

examination duties. 

FRB Hired approximately 150 examiners in 2017; however, they were all for 

existing examiner positions. No new examiner positions were added in 2017.

CFPB Hired 35 examiners in FY17. Currently under a hiring freeze.

SEC 2017 included an extended hiring freeze, with essentially no additional hires 

for examination duties.

OCC Hired 175 FTEs for examination duties in FY 2017.

FDIC Corporate University hired 155 Financial Institution Specialist (Assistant) 

positions into the Corporate Employee Program in 2017. These positions 

become examiners in Risk Management Supervision and Depositor 

Consumer Protection. In addition to these hires, Risk Management 

Supervision hired 10 mid-career examiners.

QUESTION 5

What is the ratio of supervisors to examiners in your agency?

As shown in the following chart, four of the seven agencies, including FCA, had the same or similar 

ratios of supervisors to examiners; FDIC had a slightly larger number of examiners to supervisors; 

and the examiner to supervisor ratios at OCC varied in each of the two supervisory divisions, with 

the midsize and community bank division having the largest ratio of examiners to supervisors and 

the large bank division having the smallest ratio.

Agency Approximate Examiner to Supervisor ratio

FCA 6 to 1

NCUA 9.5 to 1 

FRB 6 to 1

CFPB 6 to 1

SEC 6 to 1

8 FCA may hire interns, including students, each year. These interns can be converted to permanent positions 

from temporary assignments. For 2017 hires, four of the interns did not convert to permanent.
15

OCC Midsize and Community Bank Supervision is 19 to 1

Large Bank Supervision is 4.4 to 1

FDIC 8-10 to 1

QUESTION 6

How many institutions does your agency examine each year? 

As expected, given its size, FCA performs the lowest amount of examinations per year. The other 

agencies varied drastically from 172 supervisory events9

at CFPB to 6,425 examinations at FDIC.

See each agency’s responses below: 

Agency Response

FCA For 2017, OE issued 57 Reports of Examination and 42 Interim Activity Letters (this 

includes Horizontal Examination Activities and any other examination activity letter 

sent to the Farm Credit System). 

NCUA NCUA completed 5,238 on site visitations including examinations and interim 

supervision contacts in 3,727 credit unions during 2017. NCUA employs a deferred 

examination cycle for well-run, low risk credit unions which results in a portion of the 

5,800 credit unions receiving an exam approximately every 18 months.

FRB The Federal Reserve System conducted 3,180 exams and inspections in 2017. An 

institution may have more than one exam/inspection in a year.

CFPB The Bureau initiated 172 supervisory events at financial services institutions in FY 

2017.

SEC We are responsible for over 30,000 registrants. In FY 2017, SEC’s Office of Compliance 

10 Inspections and Examinations completed over 2,870 examinations. 

OCC In calendar year 2017, Midsize and Community Bank Supervision examined 938 

institutions. All Large Bank Supervision institutions are on an annual examination cycle; 

Large Bank Supervision examines 20 National Banks/Federal Savings Associations and 

57 Federal Branches/Agencies.

FDIC In 2017, Risk Management Supervision conducted 1,611 Safety and Soundness 

examinations, 347 Trust Department examinations, 1,627 Information Technology and 

Operations examinations, and 1,640 Bank Secrecy Act examinations (5,225 total 

examinations). Depositor and Consumer Protection examines approximately 1,200 

institutions per year.

9 The CFPB responded to the survey with the term “supervisory events” for examination activities. 

10 SEC also reported 3,150 examinations completed in FY 18.
16

Based on the information above and the information provided to Question 111, we combined the 

two answers into the following chart showing the number of reported examination staff compared 

to the number of examinations completed. In three agencies, FCA, CFPB, and OCC, the number of 

examiners is greater than the number of examinations conducted per year. In four agencies, 

NCUA, FRB, SEC, and FDIC, the number of examinations conducted per year is greater than the 

number of examiners. More specifically, per year: 

• FCA had about 1.6 times more examiners than examinations (.6 examinations per

examiner);

• CFPB has about 1.8 times more examiners than examinations (.5 examinations per

examiner); and,

• OCC has about 2.4 times more examiners than examinations (.4 examinations per

examiner).

In contrast, the number of examinations conducted per year at the NCUA, FRB, SEC, and FDIC 

exceed the number of examiners at these agencies. Specifically, NCUA has 7.9 examinations per 

examiner; FRB has 1.7 examinations per examiner; SEC has 2.8 examinations per examiner12; and 

FDIC has 3.2 examinations per examiner. 

11 This comparison is using Question 1 and Question 6 responses only. As noted in Question 1, some 

agencies reported headcounts instead of FTEs. Others included analytical, supervisory, and administrative 

staff in the numbers. See Question 1 for additional information.

12 SEC reported historically having more than five examinations per staff examiner based on the number of 

staff who conduct examinations full time rather than the total number of all examination staff that includes 

managers and support staff. 

163

666

1918

317

1010

2390

2017

99

5238

3180

172

2870

1015

6425

0

1000

2000

3000

4000

5000

6000

7000

FCA NCUA FRB CFPB SEC OCC FDIC

Number of employees compared to number of examinations

Number of employees Number of Examinations
17

QUESTION 7

Are examiners located in the same duty station as their supervisors?

With limited exceptions, four of the agencies, SEC, OCC, FRB, and FDIC, locate examiners with their 

supervisors. Although CFPB examiners and supervisors are located in the same regions, because 

examination staff and their supervisors are not always assigned to the same examinations, there 

may be limited in-person interaction. NCUA examiners and supervisors work remotely from their 

homes when they are not in travel status for examinations. FCA does not necessarily locate 

examiners with their supervisors.

• FCA: Examiners are not always located in the same duty stations as their supervisors.

Placement of examiners varies based on specialty, division, supervision, training, and other

needs of the office. For example, staff in OE’s Exam Policy Division, one of the smallest OE

divisions, are located in four different locations (field offices and headquarters) with only

one supervisor located in the same office as the subordinate. In contrast, OE’s Association

Examination Division places about 73 percent of its examiners at the same location with

their supervisors. In all of OE, about 56 percent of examination staff are located with their

supervisors.

• NCUA: “It varies based on the geographic distribution of credit unions. In metropolitan

areas, supervisors and examiners may have the same duty station. In large metropolitan

areas, multiple groups of examiners and supervisors may be assigned the same duty

station. In rural areas of the United States examiners and supervisors may not be in the

same duty station and may cover several states. For larger metropolitan areas, there are

often several examiners/districts. Field supervisors are generally stationed in larger

metropolitan areas as well, but they most often manage a group of examiners/districts

that will include several metropolitan areas (e.g. a whole state or multiple states).

Examiners and supervisors work remotely out of their homes.”13

• FRB: “In most cases, examiners are in the same location as their supervisor; however, there

are some exceptions for specialized needs.”

• CFPB: “Examiners are assigned to a supervisor located within their region, and typically

within the same geographic area of the region. In-person interaction may be limited, as

examiners are not always assigned to the same examinations as their supervisors.”14

13 NCUA clarified that all examiners and supervisors work remotely from their homes when not on travel 

status for examinations.

14 CFPB clarified that staff are provided support for a home office and work from home or from the 

examination site. Staff do not have a designated office, but they are allowed to use hoteling space at a 

regional office or headquarters when assigned to work in those locations.
18

• SEC: “Generally, yes.”

• OCC: “Midsize and Community Bank Supervision- Generally, yes, but it may vary by

location and position. Examiners located in headquarters, a district office, field office, or

banks (w/ resident staff) are primarily in the same location as their supervisors. Examiners

located in satellite offices are not typically in the same duty station as their supervisor since

Assistant Deputy Comptrollers are located in the field office. Shared resources, like lead

experts, are not typically located in the same location as their supervisor since their

manager is located in a district office. In addition, you may have instances where examiners

assigned to Regional Technology Service Providers are not located in the same duty

station as their supervisors. Large Bank Supervision - Most Large Bank Supervision

examiners are located in the same official duty station as their supervisor that for most

examiners is a bank location. The most notable exception is examiners in the Large Bank

Supervision Lead Expert Group who are located across the country in various large bank

cities.”

• FDIC: “In Risk Management Supervision, in the majority of cases, examiners are located in

the same duty station as their supervisors. There are exceptions with large bank institution

specialists and a limited number of examiner positions. In Depositor and Consumer

Protection, some supervisors cover two or more offices (not in all cases).”

QUESTION 8

Do you have any resident examiners (where the examiners reside on-site with the

entity they review)? If so, how many?

Five of the seven agencies, FCA, NCUA, CFPB, SEC, and FDIC, do not have resident examiners. Of 

the two remaining agencies, the OCC uses the most resident examiners while the FRB, with a small 

number of resident examiners, is transitioning away from them altogether for the largest financial 

institutions. 

• In the Midsize and Community Bank Supervision, OCC reported 17 resident examiners in

midsize institutions. The Large Bank Supervision predominantly uses resident examiners.

Approximately 500 of the 724 examiners (including 21 headquarters staff) are resident

examiners, as of May 2018. The international banking group employs a mix of resident,

on-site examiners and others that have an OCC office as their official duty station.

• FRB reported it is transitioning away from the use of examiners that reside on-site for the

largest institutions and plans to have none in the near future. Many larger banks continue

to have on-site examiners. This on-site presence ranges from one to 14 examiners. Some

banks have dedicated temporary space on-site in case it is needed. No examiners reside

on-site for the smaller institutions.
19

QUESTION 9

Please provide any other information you think would be helpful to the Farm Credit 

Administration or that impacts any of your answers to the above questions (telework, 

flexiplace, statutory requirements).

• CFPB, FDIC, FRB, SEC, and OCC provided no additional information.

• NCUA stated it plans to consolidate offices in 2019 and is targeting an 11 to 1 field

supervisor to field examiner ratio in 2019 (this would be an increase in its current examiner

to supervisor ratio of 9.5 to 1). NCUA also stated it employs a range of flexible work

schedules for field and office staff to facilitate optimal flexibility for quality of life and work

efficiency, as well as use of remote and teleworking agreements to improve efficiency.

NCUA examiners achieve fully trained status in four to five years at which time they can

apply for Principal Examiner Status (NCUA’s commissioning process). Examiners must

demonstrate complex and distressed institution examination performance, pass a written

test, and successfully pass an oral panel to achieve Principal Examiner designation. In

addition, examiners receive on average 80 hours of annual continuing education/training.

CONSIDERATIONS FOR FCA 

Based on the responses received, there may be opportunities for FCA to explore when comparing

examination staff organization and structure to gain efficiencies and savings. For example:

• NCUA’s examiners and supervisors work remotely from their homes when not in travel

status for examinations. CFPB examination staff also work remotely from their homes when

not on travel status for examinations. FCA could explore how this model could work

agency-wide or in certain areas to identify potential savings that might be gained with

field office changes or consolidations.

• NCUA is consolidating offices and increasing its target supervisor to examiner ratio.

Although FCA had similar ratios to CFPB, FRB, and SEC, NCUA and FDIC both had a larger

number of examiners assigned to a supervisor. FCA could evaluate its supervisor/examiner

ratio to identify opportunities to increase the ratio similar to those at NCUA and FDIC.

• When comparing the number of examinations performed with the number of examination

staff, NCUA, FRB, SEC, and FDIC have a greater number of examinations than examination

staff. FCA may want to study the models of those agencies for an understanding of how

efficiencies in this area could be gained.
20

APPENDIX A: OBJECTIVE, SCOPE, AND METHODOLOGY

The objective of this evaluation was to compare FCA’s examiner career structure and organization 

within the OE to other federal financial regulators. We conducted the evaluation at FCA’s 

headquarters in McLean, VA from May 2018 to March 2019. The scope of this evaluation included 

the OE at FCA and other federal financial regulators. 

We took the following steps to accomplish the objective:

• Identified and reviewed applicable laws, regulations, and directives related to the

objective.

• Identified and reviewed applicable internal FCA policies and procedures.

• Reviewed prior reviews related to the evaluation objective.

• Interviewed the Chief Examiner and Deputy Chief Examiner from the Office of Examination.

• Requested and received examination staff data from the Office of Agency Services.

• Issued surveys to:

o Consumer Financial Protection Bureau

o Federal Deposit Insurance Corporation

o Federal Housing Finance Agency (although a survey was issued, the agency elected

not to participate in the survey).

o Board of Governors of the Federal Reserve System

o National Credit Union Administration

o Office of the Comptroller of the Currency

o U.S. Securities and Exchange Commission

We judgmentally sampled federal financial regulators based on mission and supervisory 

and examination activities. Because our sample was judgmental, it cannot be projected to 

the entire population. 

• Combined survey responses with FCA information and analyzed the data.

This evaluation was performed in accordance with the Council of the Inspectors General on

Integrity and Efficiency’s Quality Standards for Inspection and Evaluation. These standards require 

that we plan and perform the inspection to obtain sufficient, competent, and relevant evidence 

that supports a reasonable basis for our findings, conclusions, and recommendations. We 

assessed internal controls and compliance with laws and regulations to the extent necessary to 

satisfy the objective. Because our review was limited, it would not necessarily have disclosed all 

internal control deficiencies that may have existed at the time of our evaluation. We assessed the 

information and data collected during the evaluation and determined it was sufficiently reliable 

given the nature of the survey. We assessed the risk of fraud related to our evaluation objective 

while evaluating evidence. Overall, we believe the evidence obtained is sufficient to provide a 

reasonable basis for our findings and conclusions based on the evaluation objective. For 

information issued to us from other agencies, we relied on the survey responses and did not 

perform additional work to validate responses. 
21

APPENDIX B: OFFICE AND EMPLOYEE NUMBERS REPORTED BY AGENCIES

Agency Offices and Employee Numbers

FCA Headquarters: 34 

Bloomington: 32 

Denver: 43 

Dallas: 31

Sacramento: 16

Other: 7

TOTAL: 163 

NCUA Region 1: 115 examiners, 12 supervisory examiners 

Region 2: 119 examiners, 13 supervisory examiners 

Region 3: 113 examiners, 11 supervisory examiners 

Region 4: 115.2 examiners, 12 supervisory examiners 

Region 5: 116 examiners, 12 supervisory examiners 

Office of National Examination and Supervision (Headquarters): 

supervisory examiners 

TOTAL: 666.215 

25 examiners, 3 

FRB Boston: 114

New York: 454 

Philadelphia: 49 

Cleveland: 102 

Cincinnati: 30 

Pittsburgh: 18 

Richmond: 108 

Charlotte: 50 

Baltimore: 7 

Atlanta: 160 

Miami: 52 

Birmingham: 1 

Chicago: 184 

Des Moines: 34 

Detroit: 18

St. Louis: 103 

Little Rock: 1 

Memphis: 1 

Minneapolis: 68 

Helena: 6 

Kansas City: 41

15 NCUA clarified that all examiners and supervisors work remotely from their homes when not on travel 

status for examinations.
22

Denver: 34

Oklahoma City: 23 

Omaha: 14 

Dallas: 70 

Houston: 18 

San Antonio: 7 

San Francisco: 79 

Los Angeles: 61 

Salt Lake City: 11 

TOTAL: 1,918 

CFPB Northeast: 80

Midwest: 75

Southeast: 85 

West: 77

TOTAL: 31716

SEC Varies by 12 offices. New York, DC, and Chicago are the largest with approximately 110-

280 staff. The remaining offices generally range between 30-70 staff. 

OCC Albuquerque:

Alexandria: 

Arlington:

Atlanta: 

Billings

Birmingham:

Blue Ash:

Boston: 

Carlsbad 

Champaign: 

Charlotte: 

Chicago: 

Cleveland: 

Dallas: 

Denver: 

Downers Grove:

Dublin: 

East Syracuse:

Edison: 

Evansville:

Fargo: 

Fort Worth: 

Houston: 

Indianapolis:

Iron Mountain:

16CFPB clarified that staff are provided support for a home office and work from home or from the 

examination site. Staff do not have a designated office, but they are allowed to use hoteling space at a 

regional office or headquarters when assigned to work in those locations.
23

Irving:

Jacksonville:

Jersey City:

Joplin:

Little Rock:

Longview: 

Los Angeles:

Louisville:

Lubbock: 

Memphis:

Miami: 

Milwaukee: 

Minneapolis: 

Monroeville: 

Nashville: 

New Orleans: 

New York: 

Oklahoma City: 

Omaha: 

Overland Park: 

Peoria: 

Phoenix: 

Pittsburgh: 

Roanoke: 

Salina:

Salt Lake City: 

San Antonio:

San Francisco:

Santa Ana: 

Schaumburg:

Seattle: 

Sioux City:

Sioux Falls: 

Southfield: 

St. Louis: 

Tampa: 

Trevose: 

Tulsa: 

Washington, DC:

West Des Moines:

Wichita: 

Wilkes Barre:

Bank Teams:

International Bank Supervision:

Lead Expert Program: 

Headquarters: 

TOTAL: 2,390 
24

FDIC Albany:

Savannah: 

Atlanta: Charlotte:

Columbia:

Raleigh: 

Richmond:

Scott Depot: 

Montgomery: 

Pensacola: 

Shelby:

Sunrise:

Gainesville:

Tampa: 

Chicago:

Cincinnati:

Columbus:

Detroit:

Grand Rapids: 

Appleton: 

Eau Claire:

 

Hopkinsville: 

Mount Vernon:

Indianapolis:

Elizabethtown:

Lexington: 

Madison: 

Milwaukee: 

Princeton: 

Chicago Regional Office

Champaign: 

Springfield:

Austin: Lubbock: 

Baton Rouge: 

Shreveport:

Dallas: 

Albuquerque 

Denver:

Houston: 

Jackson: 

Little Rock: 

Memphis: 

Knoxville: 

Nashville: 

Oklahoma City:

Tulsa: 

Cedar Rapids:
25

Des Moines:

Fargo: 

Grand Forks: 

Kansas City:

Mankato: 

Minneapolis:

Grand Island:

 

 

Omaha:

Sioux City:

Sioux Falls:

Springfield:

Columbia:

 

St Louis:

Hays: 

Wichita:

Baltimore, MD: 

Claymont:

Jamesburg:

San Juan:

Concord: 

North Boston: 

New York City: 

Syracuse: 

Harrisburg: 

Philadelphia: 

New York Regional Office:

South Boston: 

Hartford: 

Springfield: 

Wexford:

 

Los Angeles (N):

Los Angeles (W):

Orange:

Phoenix: 

 

Portland: 

Sacramento: 

Billings: 

Salt Lake City: 

San Francisco: 

Seattle: 

TOTAL: 2,017.3 
FARM CREDIT ADMINISTRATION

OFFICE OF INSPECTOR GENERAL

REPORT

Fraud | Waste | Abuse | Mismanagement

Phone: Toll Free (800) 437-7322; (703) 883-4316

Fax: (703) 883-4059

E-mail: fca-ig-hotline@rcn.com

Mail: Farm Credit Administration

Office of Inspector General

1501 Farm Credit Drive

McLean, VA 22102-5090