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#1524303 - 03/21/11 03:01 AM Regulatory Changes
Sheldon Hendrix Offline
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Sheldon Hendrix
Joined: Jun 2006
Posts: 1,194
South
Of course, when DFA was passed, we all knew that we would have a tidal wave of regulatory change to deal with, but I don't think we anticipated so much piecemealing from the FRB to address consumer issues at the pace the industry is having to deal with.

Does anyone else feel like the pace of change is almost unmanageable? The changes we're dealing with require so much infrastructure to deal with, and I feel like community banks (I believe most forum users fit that model) don't really have the resources to adequately address the volume of changes we're expected to address appropriately.

I guess I'm just venting... I like to do things right, and with the speed at which things are moving, it's frustrating to realize that there isn't really enough time to digest the changes and address them appropriately.

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#1524307 - 03/21/11 10:29 AM Re: Regulatory Changes Sheldon Hendrix
Elwood P. Dowd Offline
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Next to Harvey
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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#1524628 - 03/21/11 05:21 PM Re: Regulatory Changes Elwood P. Dowd
Rangers Fan Offline
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Posts: 345
Ken-I only wish I had as much chocolate as Lucy and Ethel had in that episode and it is probably good that we don't have missiles like Ice Man and Maverick did or we would probably be flying and trying to use them on really stressful days....how on earth are we supposed to read, translate, digest, deal with, implement, train, network, eat, sleep and somehow have a life in the middle of all of this? I don't think anyone really had a clue how this would affect the compliance professionals at the community banks who have the smaller shops (one of my auditors is convinced that the government wants to privatize all the banks anyway and I am beginning to wonder...). I am glad they are piecemealing these initiatives or we would really be overwhelmed!

Any suggestions on how to survive???? Now THAT is a seminar I would pay out of my own pocket to go to, not that I don't love yours anyway!

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#1524912 - 03/22/11 12:20 AM Re: Regulatory Changes Rangers Fan
Sheldon Hendrix Offline
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Sheldon Hendrix
Joined: Jun 2006
Posts: 1,194
South
I wonder if this is a good time to ask for a raise?? grin Or maybe some extra staff?

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#1531479 - 04/05/11 03:21 PM Re: Regulatory Changes Elwood P. Dowd
Southern gal Offline
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Joined: Mar 2008
Posts: 504
TN
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
Indy Banker Offline
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Joined: Aug 2010
Posts: 528
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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#1532889 - 04/07/11 06:24 PM Re: Regulatory Changes Indy Banker
Truffle Royale Offline

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Posts: 17,395
Misery loves company. The only thing I'm grateful for is the fact that my exam will be before 7/21 and then they won't come back till well after I've had time to either 1)figure it all out or 2)quit. Decisions, decisions.

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#1532890 - 04/07/11 06:26 PM Re: Regulatory Changes Indy Banker
Georgia Plum
Unregistered

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
Sinatra Fan Offline
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New Jersey
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. eek
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#1534128 - 04/12/11 01:47 AM Re: Regulatory Changes Indy Banker
OnTheEdge Offline
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Joined: Apr 2002
Posts: 1,677
SmallTown, USA
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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#1534129 - 04/12/11 01:57 AM Re: Regulatory Changes Sinatra Fan
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Originally Posted By: Sinatra Fan
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. eek

When I hear banks say this I remind them that even with a compliance firm keeping them updated on changes and perhaps suggesting processes, even providing policies and procedures (which would be a bit unusual), you still need someone internally to make sure all of this is implemented properly. Just telling you about it doesn't make it happen. So I agree with your eek
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The HMDA Academy
www.kaybeescomplianceinsights.com

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#1534133 - 04/12/11 02:14 AM Re: Regulatory Changes Kathleen O. Blanchard
Bullseye Offline
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Posts: 968
Yes, but good luck hiring. We tried to hire a Compliance Officer recently and got ONE application with bank compliance experience. When we offered her the position, her bank countered with a significant salary increase so she stayed. I don't blame compliance officers though. It's hard enough to manage all of this at a bank where you know the systems, staff, etc. I couldn't imagine trying to implement all of this stuff in a new environment!

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#1534136 - 04/12/11 02:31 AM Re: Regulatory Changes Bullseye
Kathleen O. Blanchard Offline

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It is a bit like a chess game right now, with the compliance officers moving around the board! And it is a more thankless task than ever. Exhausting! Speed reading skills required.
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HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1534189 - 04/12/11 01:04 PM Re: Regulatory Changes Kathleen O. Blanchard
bstritecky Offline
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Joined: Feb 2005
Posts: 313
sd
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
The Minion Offline
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The Minion
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Posts: 832
Originally Posted By: Sinatra Fan
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. eek


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!) wink
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#1534402 - 04/12/11 04:42 PM Re: Regulatory Changes The Minion
Sinatra Fan Offline
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Sinatra Fan
Joined: Jul 2002
Posts: 5,568
New Jersey
Oh, so your boss didn't teach you, someone else did? grin

Thanks for the offer. I'll keep it in mind.
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#1534490 - 04/12/11 06:17 PM Re: Regulatory Changes Sinatra Fan
AFaquir Offline
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AFaquir
Joined: Jan 2011
Posts: 763
Top of the world... and never ...
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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#1534702 - 04/12/11 09:48 PM Re: Regulatory Changes AFaquir
Still Smiling Offline
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I can relate to everything you guys have said and yes thank you BOL.
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#1534792 - 04/13/11 01:31 PM Re: Regulatory Changes Still Smiling
Burgess Offline
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Joined: Jan 2004
Posts: 1,621
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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#1534807 - 04/13/11 01:48 PM Re: Regulatory Changes Burgess
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
Deleted
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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#1535399 - 04/14/11 10:45 AM Re: Regulatory Changes manimal
Retired DQ Offline
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Turnpike Exit 10
I agree, I had to hire someone to keep up with the compliance auditing, while I am pretty much reading and in meetings most of the time. eek
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#1535430 - 04/14/11 01:01 PM Re: Regulatory Changes Retired DQ
Sinatra Fan Offline
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Sinatra Fan
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New Jersey
I've often said lately that I feel like a research assistant at times. crazy
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#1535563 - 04/14/11 03:13 PM Re: Regulatory Changes Sinatra Fan
Pale Rider Offline
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under the Lone Star
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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#1535670 - 04/14/11 04:57 PM Re: Regulatory Changes Pale Rider
Sinatra Fan Offline
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New Jersey
To be perfectly frank, it takes a lot of time, Tums, and tears.

And, of course, tension gets thrown in as a bonus. cry
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#1535678 - 04/14/11 05:08 PM Re: Regulatory Changes Sinatra Fan
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
Deleted
I respectfully submit "Tylenol" to your list. Or any other headache regimen, but figured I'd stick with the T's for thematic purposes. smile
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