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#190587 - 05/14/04 10:48 PM
Re: ABA NRCC Regulatory Questions
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Platinum Poster
Joined: May 2003
Posts: 639
South Louisiana
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David, I would be pleased to help you with this.
These are some of my exact questions that I would like to ask.
Let me know if I can help.
Thanks,
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#190588 - 05/17/04 01:18 PM
Re: ABA NRCC Regulatory Questions
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Diamond Poster
Joined: Jun 2001
Posts: 1,373
Lido Deck
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Dave, I'm willing to help with the OCC. This whole Intent to Apply issue seems crazy to me and I'd love to ask the question about that, as well as the others.
_________________________
--A bad day at sea is better than a good day at work.
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#190589 - 05/17/04 02:02 PM
Re: ABA NRCC Regulatory Questions
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Power Poster
Joined: May 2002
Posts: 3,608
Near the Land of Enchantment
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David, I'm OCC as well, but if you need me to ask a question, let me know!
_________________________
Opinions my own.
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#190590 - 05/17/04 02:18 PM
Re: ABA NRCC Regulatory Questions
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10K Club
Joined: Nov 2000
Posts: 18,762
Central City, NE
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Quote:
David, I would be pleased to help you with this.
These are some of my exact questions that I would like to ask.
Let me know if I can help.
Thanks,
Ski: What regulatory agency would you visit with?
I see that we have 2 OCC (we sure can have more than 1 - this will ensure accurate info and diffuse the responsibility from one person) and we have the FRB covered (me, but we can have more). Anyone representing the FDIC or OTS?
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#190591 - 05/17/04 02:20 PM
Re: ABA NRCC Regulatory Questions
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100 Club
Joined: Nov 2000
Posts: 176
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David, I'll do the OTS Session.
_________________________
...but I saved a lot on my auto insurance
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#190592 - 05/17/04 02:45 PM
Re: ABA NRCC Regulatory Questions
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Power Poster
Joined: Nov 2001
Posts: 7,983
FINALLY ABOVE the gnat line
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Oh, don't worry, David. I had already planned to ask the FDIC about the HMDA/refinancing issue.
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"Once you learn to read, you will be forever free." - Frederick Douglass
My Opinion Only.
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#190593 - 05/17/04 02:45 PM
Re: ABA NRCC Regulatory Questions
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Platinum Poster
Joined: May 2003
Posts: 639
South Louisiana
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David,
Sorry I forgot in my excitement to say that I'm FDIC.
I've also sent you an e-mail with some information regarding the FDIC refinance saga.
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#190594 - 05/17/04 03:06 PM
Re: ABA NRCC Regulatory Questions
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Power Poster
Joined: Apr 2001
Posts: 4,828
Between the lines
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My state compliance group rec'd a message from the FDIC examiner on April 30 regarding HMDA refi definition.
"I just wanted to let you know that we received notification that the HMDA refinance definition the FDIC is using will not be the "relation-back" rule that requires the old deed of trust to be cancelled before a refinance occurs."
Of course that does not address the issue of what to do with all those loans that did not get coded for the first 4 months of the year. Sooooooo glad to be OCC.
_________________________
NOLA is my Beach!
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#190596 - 05/17/04 06:47 PM
Re: ABA NRCC Regulatory Questions
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Power Poster
Joined: May 2002
Posts: 3,608
Near the Land of Enchantment
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David,
I'm assuming you just forgot cwilliams and me under OCC?
_________________________
Opinions my own.
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#190597 - 05/19/04 01:30 AM
Re: ABA NRCC Regulatory Questions
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10K Club
Joined: Nov 2000
Posts: 18,762
Central City, NE
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Quote:
David,
I'm assuming you just forgot cwilliams and me under OCC?
Please forgive me. I got interrupted and didn't pick up where I left off. Thanks for bringing this to my attention.
Does anyone have any questions that would like for us to ask?
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#190598 - 05/19/04 03:10 PM
Re: ABA NRCC Regulatory Questions
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Anonymous
Unregistered
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David and others lucky enough to be attending the conference,
Any chance you could ask the regulators TOTALLY OFF THE RECORD what they think the odds are that the small bank/large bank threshold will get raised to $500MM. And also, any idea on when we would hear a decision on that issue one way or the other? (ie., by end of year, within 18 months, 2-years, when hell freezes over, etc.). Even knowing when there may be a decision on it will help our planning because we are currently at 230MM.
Thanks everybody.......
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#190599 - 05/19/04 06:30 PM
Re: ABA NRCC Regulatory Questions
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10K Club
Joined: Aug 2002
Posts: 34,318
under the Lone Star
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Anon: According to a story in today American Banker, it will move to $500 million when hell freezes over. Twenty-nine demos (and the lone independent) wrote letters to all the federal regulators demanding that the current CRA proposed changes be dropped from consideration because of the harm it would cause to LTM communities across the country (this is a barf alert).
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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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#190600 - 05/19/04 06:41 PM
Re: ABA NRCC Regulatory Questions
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Anonymous
Unregistered
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Don, Thanks for the laughs. What did you mean by "29 demos" (and the lone independent)....?
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#190601 - 05/19/04 06:59 PM
Re: ABA NRCC Regulatory Questions
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10K Club
Joined: Oct 2000
Posts: 27,748
On the Net
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Democrats.
This will be interesting. I see a lot of consumer group input on this. They like that low threshold and a recent FDIC speech said 8,000 of the nations 9,000 banks are under $500MM. Raising that number makes things much easier for bankers, but will reduce the ammo in the gun put to the banker's "new and innovative" head.
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#190602 - 05/19/04 08:35 PM
Re: ABA NRCC Regulatory Questions
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10K Club
Joined: Aug 2002
Posts: 34,318
under the Lone Star
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Andy is correct, I should have been more clear. It is 29 democrat senators and the one independent. That is a sizable group of senators.
_________________________
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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#190603 - 05/19/04 10:54 PM
Re: ABA NRCC Regulatory Questions
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10K Club
Joined: Nov 2000
Posts: 18,762
Central City, NE
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Quote:
David and others lucky enough to be attending the conference,
Any chance you could ask the regulators TOTALLY OFF THE RECORD what they think the odds are that the small bank/large bank threshold will get raised to $500MM. And also, any idea on when we would hear a decision on that issue one way or the other? (ie., by end of year, within 18 months, 2-years, when hell freezes over, etc.). Even knowing when there may be a decision on it will help our planning because we are currently at 230MM.
Thanks everybody.......
We'll add it to the list. Good question.
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#190604 - 05/21/04 05:36 PM
Re: ABA NRCC Regulatory Questions
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Anonymous
Unregistered
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A possible CIP question. In the "Frequently Asked Questions" CIP guidance issued by regulators January 2004, a question was asked about the situation where a person has had an account in the last twelve months but no longer has an account. The answer included the statement "a person would not be deemed to have an existing account at the bank if the person had a loan, paid it off, and twelve months later obtains a new loan." Was the intent to establish a specific twelve month time standard, or was this just a hypothetical example for guidance? What if the person comes back a week later, or two years later? Our bank believes we should be able to apply common sense to this situation. Once we have formed a reasonable belief that we know the customer's true identity and have that customer in our records, we don't think that person's identity can change just because time has elapsed.
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#190607 - 06/04/04 02:43 PM
Re: ABA NRCC Regulatory Questions
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Diamond Poster
Joined: Apr 2002
Posts: 1,677
SmallTown, USA
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Hope you are soon on the mend !
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The opinions expressed are mine and do not necessarily reflect those of my employer.
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#190609 - 06/04/04 03:15 PM
Re: ABA NRCC Regulatory Questions
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Power Poster
Joined: May 2002
Posts: 3,608
Near the Land of Enchantment
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David, I hope you bounce back quickly! I was really looking forward to meeting you tomorrow night! I have my question printed off and ready to go with me, though. I'll ask it in the OCC breakout!
_________________________
Opinions my own.
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