those areas of consumer compliance where problems are uncommon, although we are ready to ramp up that scrutiny if we have concerns about practices at a particular institution. since making these changes 16 months ago, the average length of time for examinations has dropped, and the feedback we have heard from you is mostly positive. bankers have told us that the examiners seem to have a better grasp of the key issues and that exams are, as we intended, more closely tailored to the business characteristics and risk profile of individual institutions. examiners also tell us they sometimes see increased consumer compliance risk at community banks that are expanding beyond their traditional product offerings, often using outside vendors to introduce new products such as prepaid cards or credit card add - ons. these products are often complex, and community banks may not always be familiar with the risks the products pose. banks may not have sufficient expertise to thoroughly check out a vendor and monitor its performance. beyond consumer compliance supervision, the federal reserve has expanded our ability to conduct more of the work of bank examinations off site. if banks have electronic loan records, it is possible for examiners to assess loan quality and underwriting practices remotely, spending much less time on site. this approach has the potential to improve examination efficiency and to reduce the examination - related disruption to banking more on the large institution supervision coordination committee is available on the board ’ s website at www. federalreserve. gov / bankinforeg / large - institution - supervision. htm. bis central bankers ’ speeches operations. however, if banks prefer more face - to - face interaction with examiners – and there are banks that do – we will continue the traditional on - site review. our efforts to further tailor bank supervision at community banks continue. staff members from the federal reserve, office of the comptroller of the currency, and federal deposit insurance corporation are working through a major review of regulations called for in the economic growth and regulatory paperwork reduction act ( egrpra ). we are still in the midst of this effort, which is being conducted with a broad mandate to identify and revise where possible outdated, unnecessary, or unduly burdensome regulations, including those that apply to community banks. the agencies are carefully considering public comments. although some burden - reducing measures may require congressional action, the agencies will act to implement regulatory relief when possible before the end of the egrpra review period. the results of our egrpra review will be included in the agencies ’ joint

small bank holding company policy statement and apply it to certain savings and loan holding companies, ” press release, april 9, www. federalreserve. gov / newsevents / press / bcreg / 20150409a. htm. bis central bankers ’ speeches firms. this system helps community banks by eliminating requirements that are relevant only to large, geographically diversified banks. this tiered approach allows us to account for the differences in business models and risk levels among different types of banks. our goal is not to develop one state - of - the - art approach to regulation and supervision, but instead multiple state - of - the - art approaches that are appropriate for each type of institution we oversee. supervision of community banks is not a watered - down version of supervision of larger banks, but a significantly different process tailored to the business model of smaller banks. for community banks, the primary purpose of prudential regulation is to ensure the safety and soundness of each individual institution, thereby protecting the deposit insurance fund. the crisis showed that such a focus on individual institutions was inadequate to account for and contain the systemic threats posed by risks at larger, more complex institutions, and much of the improvement in oversight has been directed at systemic risk. the board is committed to making sure that new supervisory standards do not trickle down to community banks when they may only be appropriate for larger institutions, whether they be systemically important institutions overseen by the large institution supervision coordination committee, other large banking organizations with more than $ 50 billion in assets, or regional banking organizations with between $ 10 billion and $ 50 billion in assets. 3 for example, the board has made it clear that capital stress tests and other aspects of the comprehensive capital analysis and review requirements do not apply to community banks, either explicitly or implicitly. in addition to board members making this point in public speeches and in meetings with bankers, the federal reserve ’ s examiner training emphasizes that these requirements, which were established under the dodd - frank act, will apply only to large banking organizations. the fed also made changes in 2014 to better tailor our program of consumer compliance supervision of smaller institutions. under the new approach, the intensity of bank examinations is based on our assessment of the risk profile of individual community banks, including how each identifies and manages consumer compliance risk. risk assessment begins before examiners arrive at the bank, allowing examiners to focus on higher - risk concerns at the banks they supervise. we have also directed examiners to spend less time on