Banking and Economy Stress Disorder
Banking and Economy Stress Disorder
by Kathy Emery & Mary Beth Guard
Any day now, the regulators will probably release a bulletin advising bankers to gear up for a full-fledged epidemic of BESD. Indeed, cases of the dreaded malady have already been detected in random financial professionals across the country. I'm waiting to be quarantined myself because I confess, I have it, too - Banking and Economy Stress Disorder.
A few years back I had a related condition -- CRADD. The penalties (oops, I mean symptoms) for it were much milder than those of BESD.
At first, I thought I'm just having one of THOSE days but then one of THOSE days was every day!! The symptoms start slow, at first it's just here and there. Take the Reg Flags. No, take the Reg Flags -- please! Can I get out of the Reg Flags if I'm certified as a "section 114"? Instead of counting sheep, I'm detecting red flags to fall asleep. The FACTA deadline is Nov 1st. Now that's a nightmare I can't wake up from.
Okay take a deep breath. It's okay. It's okay. Where are my antacids?
Oh, gee! Time to study the major amendments to Reg Z and the proposed new credit card rules. We have to confirm the borrower's ability to repay under the new rules. Are you telling me we haven't been doing that? We've just been making loans to people who assure us they can handle it? When was that ever a good idea?
I never knew I'd have to study so much for a job. It makes me miss finals in college. At least when they were over we had a kegger and a bonfire. Hey! A bonfire would take care of some of our record retention issues. But I digress.
Yikes!! Big time RESPA disclosure changes are in the works. Just what we need --"Closing Scripts" to be read aloud to customers. I always hoped I could have "Story time with Kathy." I just didn't dream the "story' would be all about closing costs. Would it be >
HUD is proposing all new GFE forms & HUD-1/1A Charges Comparison Charts. The software and training will cost us a bundle. Millions, billions, trillions. What's a few 0's between friends? So much to look forward to: RESPA II: Back with a Vengeance!
The lobby is empty because the news reports have made customers think we wouldn't give them a loan if they asked for one. The only ones with guts to come in are the identity thieves. Hey, our Red Flags program is supposed to detect them. Man, I've got to get that sucker done?
Fannie Mae, Freddie Mac, bank failures, bank buyouts, the stock market, the bailout bill, insecurity over securities and 401Ks, the 24/7 cable news channels have the customers running scared, so we've ended up with more than a few coming in and thinking they would be better off taking all their money out of the bank. Oh, yeah. That's a bright idea. The last one finally went away after we convinced him his money was going to be safer in the bank than under his mattress!!! I could be wrong, but I doubt that his mattress tag has the member FDIC logo on it.
Speaking of FDIC, we had recently conducted deposit insurance coverage training for our entire frontline. Employees were armed with information and brochures and totally ready to respond to questions. Then . . . it . . . all . . . changed. Well, maybe not all, but enough that we're having the recycler pick up all the old brochures. Memo to employees re last week's deposit insurance training: "Never mind." And what's with that "$500,000" test on revocable trusts with more than 5 beneficiaries? Oh, yeah. It's not even $500,000 any more. Now it's $1,250,000. Well, doesn't that make the math special?
Even the bank president got scared. I tried to teach him to use EDIE but he's going to wait for the FDIC to send him the info on a 78 and he can play it on his Victrola. I'm sure the Pony Express will have it delivered in no time.
Oh yeah. Note to self. There are still more pending rules hanging over our head - risk-based pricing notices under FACTA, direct dispute resolution, accurate credit reporting. We've got to train! Train! Train! Speaking of trains?.. Is that a light at end of the tunnel? I hope it's not an oncoming train. I think I need a drink!
And we have to get ready for the examinators, errrrr, I mean examiners. What's on the list? Where's the list? Oh, not that list. That's the list of drugs I have to ask my doctor if they're "right for me."
Achoo!! Did I just sneeze? Oh no. I can't get sick. Where's the flu pandemic kit? My family already thinks I'm sick because I tend to talk only in unintelligible acronyms - ARM, CHARM, TILA, RESPA, ECOA, HMDA, AML, BSA, HELOC, POA, ITF, ATF, ODP, CIP, FDIC, NCUA, OCC, OTS, FRB, FTC, EFTA, EFAA, FACTA. My vocabulary is not dinner table friendly. And did you know that not everyone finds it fascinating that defeating contingencies were eliminated several years ago and now the concept of qualifying beneficiaries has also been removed? It's so hard to have good conversations these days.
If all this stress keeps up I'm about ready to join the "will work for food" crowd. Maybe marketing can make me a sign. Will my sign require disclosures? Does it have to state when "I will or will not work for food" and "for how long"?? Is "food" a trigger term? If I use it, do I have to disclose what kind of food? Do I have to give a change in terms notice if I get hungry for something else and change my mind? I wonder what Reg I'd find that in? I think I'll post that on the General Discussion Board.
And I'm so tired of politics. ????.Nuff Sedd.
Copyright, Bankers Online. First published on BankersOnline.com 10/10/08
First published on 10/10/2008