bis central bankers ’ speeches i believe bankers come to fully understand supervisory expectations over time, as their experience grows. but when something radically changes the supervisory landscape such as new regulations, drastic changes in the economic environment, or reassignment of regulatory authority, more direct outreach might be needed. for many years, the reserve banks have maintained local training and outreach programs for banks in their districts. for instance, the popular “ ask the fed ” calls conducted by the federal reserve bank of st. louis provide bankers with an opportunity to hear federal reserve staff discuss recent policy initiatives and to be updated on the most common problems that examiners see in the field. the calls also provide an informal setting for bankers to ask questions on issues of concern. in addition, consumer compliance webinars have provided a forum for the federal reserve to discuss emerging consumer compliance issues and to answer questions from webinar participants directly. 3 these initiatives have been so successful that a planning group is studying options for leveraging these efforts in a coordinated, national initiative to improve communication of relevant information to community banks supervised by the federal reserve. despite all efforts to communicate supervisory expectations, there are inevitably disagreements between banks and their examiners about examination findings. the federal reserve ombudsman actively works with banks that have concerns about their examinations or that wish to appeal an examination finding. the ombudsman works independently from the bank supervision chain of command and has broad authority to mediate complaints, including the authority to refer matters to committees of the board. the ombudsman ’ s office also has a follow - up program in place to protect the banks that contact it from retaliation. and the ombudsman tracks the nature and source of complaints in order to identify potential systemic problems. 4 balancing safety and soundness with credit availability since 2008, many banks have seen their assets ’ quality criticized and their ratings downgraded. this is not surprising given the severity of the economic downturn and the effect it had on the quality of bank assets. however, some bankers complain that examiners also tightened their approach. indeed, we repeatedly hear that fear of examiner criticism is one of the reasons banks hesitate to lend to small businesses. we take these concerns seriously. in response, we are actively communicating with examiners and have stepped up examiner training to ensure that supervision in the field is consistent with policy. at the same time, i think it is important to continually reevaluate our supervisory policies and procedures to ensure that the policies themselves are

htm ; bbva, “ bbva api market, the platform for financial innovators, ” press release, may 4, 2016, www. bbva. com / en / news / general / bbva - api - market - platformfinancial - innovators / ; mark boyd, “ capital one launches first true open banking platform in u. s., programmable web, ” march 11, 2016, www. programmableweb. com / news / capital - one - launches - first - true - open - banking - platformus / 2016 / 03 / 11 ; penny crosman, “ fintech glasnost : why u. s. banks are opening up apis to outsiders, ” american banker, july 8, 2015, www. americanbanker. com / news / fintech - glasnost - why - us - banks - are - opening - up - apis - tooutsiders ; see also pymnts. com, “ mastercard turns up the api volume, ” september 28, 2016, www. pymnts. com / mastercard / 2016 / mastercard - turns - up - the - api - volume / ; visa inc., “ visa opens its global network with launch of visa developer, ” press release, february 4, 2016, www. businesswire. com / news / home / 20160204006175 / en / visa - opens - global - network - launch - visa - developer. indeed, over five years ago, french bank credit agricole used open apis to launch an app store of its own. the bank even connects its customers with developers, using message boards so that customers ( or even other banks ) can post ideas for developers to build. see, e. g., karen epper hoffman, “ open api for bank apps : can credit agricole ’ s model work here? ” american banker, july 29, 2013 ; ca store, www. creditagricolestore. fr / catalogue - dapplications. html ( last visited april 4, 2017 ) ( as of april 2017, the site features 47 apps and 62 ideas ) ; mary wisniewski, “ will banks become app stores? this de novo wants to, ” american banker, february 18, 2016, www. americanbanker. com / news / will - banks - become - app - stores - this - de - novo - wants -