National Bank Surveillance System (NBSS)

National Bank Surveillance System (NBSS)

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What Was the National Bank Surveillance System (NBSS)?

The National Bank Surveillance System (NBSS) was a computerized monitoring system developed to collect data and evaluate the financial performance of national banks. The off-site surveillance system was first established by the U.S. Office of the Comptroller of the Currency (OCC), a federal agency that oversees the execution of laws relating to national banks, in 1975. The OCC has phased out its use of the NBSS and replaced it with the Uniform Bank Performance Report (UBPR).

Key Takeaways

  • The National Bank Surveillance System (NBSS) was a computerized monitoring system developed to evaluate the financial performance of national banks.
  • The off-site surveillance system was created in 1975 by the U.S. Office of the Comptroller of the Currency (OCC).
  • Computerized systems enabled regulators to analyze the enormous amounts of data that banks reported.
  • The NBSS's quarterly Bank Performance Report compared each bank to a group of its peers, making it easier to spot signs of financial trouble.
  • The OCC now uses the UBPR instead.

Understanding the National Bank Surveillance System

The National Bank Surveillance System (NBSS) acted as an early warning system. Its task is to identify banks displaying signs of financial trouble. It would alert regulators so they could take action and step in before the bank failed or experienced other trouble.

The National Bank Surveillance System's (NBSS) primary tool was its quarterly Bank Performance Report, which compared each bank to a group of its peers. This allowed regulators to develop an accurate picture of how banks were individually faring. Information was often sourced from Call Reports. These are financial health updates that banks are obligated to file on a quarterly basis.

The off-site surveillance system analyzed and predicted capitalization ratios, equity ratios, and other quantifiable pieces of information in order to understand which banks were in danger of failure. Ideally, the National Bank Surveillance System (NBSS) would notify the OCC of any red flags before it was too late.

Newer models allow regulators to predict a bank's probability of failure over the following two years.

The Office of the Comptroller of the Currency

The purpose of the OCC is to promote a safe and reliable national banking system in the United States. The OCC charters, regulates, and supervises all U.S. national banks, conducting on-site reviews and stringent oversight of their operations.

According to the OCC, banks are normally subject to a full-scope, on-site examination every 12 or 18 months. In theory, banks that were highlighted by the National Bank Surveillance System (NBSS) system as displaying signs of distress would have their on-site examinations pushed forward to an earlier date.

History of the National Bank Surveillance System

The National Bank Surveillance System (NBSS) made its debut after the failure of two national banks in the early 1970s. The OCC, facing considerable scrutiny for not foreseeing these shortcomings, commissioned a study from the accounting firm Haskins & Sells. The report, issued in 1975, recommended that banks provide more updates. The report also championed the creation of a computerized, off-site system, noting that the cost and difficulty of analyzing Call Reports via computer had dropped significantly over the past decade.

A decade after the report was issued, the savings and loan (S&L) crisis occurred. Between 1986 and 1995, more than 1,000 savings and loan associations in the United States collapsed. This devastating chain of events made it clear that off-site surveillance was not sufficient to accurately predict bank failure. It needed to be accompanied by frequent, periodic, on-site examinations.

The cake celebrating the OCC's 120th anniversary was in the shape of a computer, illustrating just how dependent the federal agency had become on the National Bank Surveillance System's (NBSS) ability to analyze Call Reports.

Studies since the 1980s have found that frequent on-site examinations make for more accurate Call Reports, as they allow bank examiners to scrutinize loans closely and encourage banks to report loan losses in a timelier fashion.

Changes to the National Bank Surveillance System (NBSS) during the 1990s allowed regulators to more closely monitor banks between periodic on-site examinations. This allowed them to determine whether an additional, unscheduled examination was warranted to surveil a particular bank.

Eventually, the National Bank Surveillance System (NBSS) was transformed into the Uniform Bank Surveillance System (UBSS). The Bank Performance Report became the Uniform Bank Performance Report (UBPR).

Who Controls the National Banking System?

The Office of the Comptroller of the Currency (OCC) is an independent part of the U.S. Department of the Treasury. It is responsible for chartering, regulating, and supervising all national banks, federal savings associations, and federal branches and agencies of foreign banks.

Are National Banks Controlled by the Government?

The Federal Reserve banks exist because of an act of Congress, but they are not controlled by the federal government. The Board of Governors of the Federal Reserve is an independent government agency, but the Federal Reserve banks are set up like private corporations in that members can hold stock in the bank and earn dividends. However, this stock does not come with the control and financial interest that most for-profit stocks do.

Who Investigates Banks?

If a complaint or inquiry is filed against a bank, the Federal Deposit Insurance Corporation (FDIC) will investigate the complaint if the bank is FDIC-insured. If the bank is not primarily regulated by the FDIC, the investigation will be handled by another federal banking regulator. These include the OCC, the Federal Reserve, and the National Credit Union Administration (NCUA).

The Bottom Line

The National Bank Surveillance System (NBSS) was a system that evaluated the financial performance of national banks through computer monitoring. It was created in 1975 by the U.S. Office of the Comptroller of the Currency (OCC).

The NBSS was an off-site system that allowed regulators to analyze data that banks reported and spot signs of financial trouble. It was paired with periodic on-site surveillance. Eventually, the NBSS became the Uniform Bank Surveillance System (UBSS).

Article Sources
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  1. Federal Financial Institutions Examination Council (FFIEC). "UBPR."

  2. Federal Reserve Bank of St. Louis. "Are the Causes of Bank Distress Changing? Can Researchers Keep Up?" Pages 58, 60.

  3. Federal Deposit Insurance Corporation. "Chapter 13 Off-Site Surveillance System," Page 478.

  4. Office of the Comptroller of the Currency. "What We Do."

  5. Office of the Comptroller of the Currency. "Examinations Overview."

  6. Federal Deposit Insurance Corporation. "Chapter 13 Off-Site Surveillance System," Page 477-479.

  7. Federal Reserve History. "Savings and Loan Crisis."

  8. Federal Deposit Insurance Corporation. "Chapter 13 Off-Site Surveillance System," Page 478-479.

  9. Federal Reserve Bank of St. Louis. "Are the Causes of Bank Distress Changing? Can Researchers Keep Up?" Page 60.

  10. Federal Financial Institutions Examination Council. "UBPR."

  11. Office of the Comptroller of the Currency. "About Us."

  12. Federal Reserve Bank of St. Louis. "Making Sense of the Federal Reserve: Who Owns the Federal Reserve Banks?"

  13. Federal Deposit Insurance Corporation. "Welcome to the FDIC Knowledge Center: Q: How Do I File a Complaint Against a Bank?"

  14. Federal Reserve Bank of San Francisco. "Are All Commercial Banks Regulated and Supervised By the Federal Reserve System, Or Just Major Commercial Banks?"

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