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#1524307 - 03/21/11 10:29 AM
Re: Regulatory Changes
Sheldon Hendrix
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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My cinematic analogies are Lucy and Ethel packing chocolates and Ice Man telling Maverick "We are totally defensive" and "I'm in deep xxxx" in the middle of a dogfight.. The Chairman of the House Financial Services Committee has written to six financial agencies that he is "troubled by the volume and pace of Dodd Frank Act rulemaking." Obviously, DFA is the wellspring of change, but not its only source. The FDIC has chosen this as the time to issue poorly written "guidance" on a subject it is not empowered to regulate and regulations governing the handling of third party claims on government funds have been issued with a lead time that is simply impossible. The FRB has issued a 500 page proposal for changes to model forms that should have been effected more than a year ago, but it also incorporates a push toward the adoption of electronic presentment for all banks. Then, there's that thing about a new consumer protection agency that is so confused that it's meeting with religious leaders in an attempt to figure out its mission. I have never seen this before. Today I'm speaking to a group of directors about the plight of the compliance officer and I'm finding it difficult to figure out where to stop...
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#1531479 - 04/05/11 03:21 PM
Re: Regulatory Changes
Elwood P. Dowd
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Platinum Poster
Joined: Mar 2008
Posts: 504
TN
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Ken, any suggestions for putting together something for my board regarding the all the new compliance issues facing banks. or anyone else willing to share?
Last edited by Southern gal; 04/05/11 05:42 PM.
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#1532885 - 04/07/11 06:17 PM
Re: Regulatory Changes
Southern gal
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Platinum Poster
Joined: Aug 2010
Posts: 528
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I've been in charge of regulatory compliance for my bank ($375 million) since 1996, so I would consider myself a seasoned veteran of compliance. I can tell you, however, that I have never felt so insecure about our efforts to remain in compliance as I do now. It is frustrating because we are trying so hard to comply, but we don't have the luxury of in-house legal counsel and thus left to decipher and attempt to interpret this on our own. Thank goodness for BOL and similar bank trade group sites! I think we all agree that some change and reform was needed, but it seems like the regulations have been written in such a way that go way beyond what Congress intended. If the intent of Congress was to encourage community banks to stop offering certain products, then I guess they have succeeded, as our bank has ceased making education loans, reverse mortgage loans, and some home equity installment loans simply because of the heightened disclosure and compliance requirements. And now because of the new broker compensation regulation, we might abandon our FHA lending altogether as well. I can only imagine how much worse it is going to get the closer we get to July 21 and beyond....
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#1532890 - 04/07/11 06:26 PM
Re: Regulatory Changes
Indy Banker
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Georgia Plum
Unregistered
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Same her bikb-4life. We've closed our mortgage department already. We don't do education or reverse mortgages. We're almost to the point of stopping all consumer lending and jusst concentrate on commercial and small business. I grew up in deposits, not loans, so I've never been as comfortable with loan compliance and now with all the changes, I don't know which end is up anymmore.
I thank God for BOL as well!!!
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#1533009 - 04/07/11 08:31 PM
Re: Regulatory Changes
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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We are a $1 billion community bank, with no one whose full-time job is compliance. Each department head handles compliance responsibilities along with his or her managerial duties. Now, we think we have finally convinced the board that we need to hire a full-time compliance officer. The suggestion has been floated that, as an alternative, we could contract with a third-party service provider for this.
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Management is doing things right; leadership is doing the right things. Peter Drucker
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#1534128 - 04/12/11 01:47 AM
Re: Regulatory Changes
Indy Banker
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Diamond Poster
Joined: Apr 2002
Posts: 1,677
SmallTown, USA
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I too have been in the Compliance arena for many years. Up until the last couple of years I was fairly comfortable with my level of knowledge, but lately not so much. Our last compliance exam went VERY well.We are scheduled for another very soon.....I can't imagine how much different the process and the outcome will be. Can you say OVERWHELMED?????
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The opinions expressed are mine and do not necessarily reflect those of my employer.
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#1534189 - 04/12/11 01:04 PM
Re: Regulatory Changes
Kathleen O. Blanchard
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Gold Star
Joined: Feb 2005
Posts: 313
sd
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i agree with all your comments. As a compliance officer for a $1Billion+ bank, I no longer have the same comfort level with our compliance efforts than I once did. With that being said, does anyone out there have any great resources that I could use to help educate my board on the volume of regulatory changes we have done for the last 3years and what is still to come? I have to do a presentation to our board risk committee in a very short time frame and trying to find something that sums up all the work community banks have had to do and commnicate to them the risks that are still there.
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#1534192 - 04/12/11 01:12 PM
Re: Regulatory Changes
Sinatra Fan
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Platinum Poster
Joined: Sep 2009
Posts: 832
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We are a $1 billion community bank, with no one whose full-time job is compliance. Each department head handles compliance responsibilities along with his or her managerial duties. Now, we think we have finally convinced the board that we need to hire a full-time compliance officer. The suggestion has been floated that, as an alternative, we could contract with a third-party service provider for this. I'm here for you, if you need someone. I have a great teacher, so you can be sure that I am up for the job! (Just don't tell my boss!)
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#1534402 - 04/12/11 04:42 PM
Re: Regulatory Changes
The Minion
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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Oh, so your boss didn't teach you, someone else did? Thanks for the offer. I'll keep it in mind.
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Management is doing things right; leadership is doing the right things. Peter Drucker
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#1534490 - 04/12/11 06:17 PM
Re: Regulatory Changes
Sinatra Fan
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Platinum Poster
Joined: Jan 2011
Posts: 763
Top of the world... and never ...
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Call it Naive, call it "devil-may-care" but my approach to all this has been... I will address everything as needed and when needed and not a second sooner. Totally agree that the rules will be massively difficult to implement, train, digest, suffer, error correct... but IMO that is the job I signed up for.
If I wanted to do nothing and get paid for it, I'd be writing the Regs, not interpreting them (hahahaha I kid, I kid).
But in all honesty did any of us really expect to write a policy once? We are in the interpretation business so our policies should be reviewed constantly, one off situations that challenge the rigidity of our policy should be a weekly occurrence! I for one log on to BOL for two reasons, one to get help when I'm stuck and two to challenge myself to help others solve problems that I have had or would want to know the answer to, all the while learning from both.
Cheers!
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In life, there is a lot less that could get better and a lot more that could get worse.
MBA Fin/MBS HR
My views only!
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#1534702 - 04/12/11 09:48 PM
Re: Regulatory Changes
AFaquir
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Platinum Poster
Joined: Nov 2007
Posts: 767
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I can relate to everything you guys have said and yes thank you BOL.
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Comments are strictly my own and not that of my employer.
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#1534792 - 04/13/11 01:31 PM
Re: Regulatory Changes
Still Smiling
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Diamond Poster
Joined: Jan 2004
Posts: 1,621
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i am a compliance officer with a almost 1 billion dollar bank. several years ago i saw my job as reviewing various files and documents to make sure we were compliant. But beginning with the rules that started coming in 2008 and we became a hmda reporter in 2008, my role changed to continual training, working with departments to put procedures in place to cover the new rules, re-training because the first training didn't stick, reviewing proposed rules.... The auditing now has become more of a assigning audit projects to a outside cpa firm we outsourced our internal audits to, and to assign various departments responsibilty to do self audits and provide me with their workpapers and results. and then of course more re-training. So, yeah i am the compliance officer with no staff, but i have taken the approach that compliance is everyones job. Imagine i put the "rant" face here.
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My views, not my employer's views.
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#1534807 - 04/13/11 01:48 PM
Re: Regulatory Changes
Burgess
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Diamond Poster
Joined: Feb 2008
Posts: 2,207
Deleted
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I agree burgess, when I first started in Compliance I spent most days with my head buried in loan and deposit files reviewing for compliance. Now my day always starts with reviewing various resources (ABA, BOL, etc.) for what new proposed or final rule has been released. I keep a giant spreadsheet to track regulatory changes, am in constant communciation with other departments regarding policy updates and training, and honestly spend more time reading new regulations than reviewing files. The focus has shifted for sure!
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We're all here 'cause we've lost control.
Innerpartysystem
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#1535563 - 04/14/11 03:13 PM
Re: Regulatory Changes
Sinatra Fan
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10K Club
Joined: Aug 2002
Posts: 34,318
under the Lone Star
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In these difficult economic times, it's good to have a job, but I really can't fathom how y'all keep up on this stuff.
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Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.
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#1535670 - 04/14/11 04:57 PM
Re: Regulatory Changes
Pale Rider
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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To be perfectly frank, it takes a lot of time, Tums, and tears. And, of course, tension gets thrown in as a bonus.
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Management is doing things right; leadership is doing the right things. Peter Drucker
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