Don Blaine is the Senior Training Consultant for Compliance Resource, LLC, a source of compliance assistance for financial institutions. Don has over 30 years of experience in regulatory compliance for the banking industry with banks ranging in size from community banks to money center banks. He is considered a subject matter expert in many of the consumer affairs laws and regulations and will be primarily specializing in training activities that will encompass the Bank Secrecy Act/Anti-Money Laundering laws and regulations as well as many of the laws and regulations related to deposit compliance. His prior roles have included: Chief Compliance Officer, Senior Compliance Regulatory Examiner, Compliance Audit Manager, and business unit compliance manager. He has taught at the ABA’s National Compliance School and has also served as an instructor on BSA and compliance topics at various programs offered by state banking associations. Prior to joining Compliance Resource, LLC, Don served as a consultant to numerous banks in areas ranging from BSA to lending and deposit compliance. He has attained Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) certifications.
What are the starting blocks for the development of what my annual compliance audit plan or my compliance monitoring plan for the next year in terms of regulations, products, business units, etc by the compliance monitoring program or the compliance auditing annual plan?
A large amount of our bank’s Net Income Before Taxes and Extraordinary Items, shown on our Call Report or in general ledgers, consists of fees associated with the automated ODP product. Is this of any concern to our regulatory agencies and do we need to be monitoring the impact of overdraft fees to our bottom line?
At what point in the process do we start conducting due diligence on loans and does it differ between loan and deposit accounts?
Much of the guidance regarding automated overdraft speaks to “alternative products”. What are these products and are we required to have them and how do we advertise them to our account holder base?
Does the Interagency Exam Manual for BSA include any training requirement for lenders?
Does the assessment of an automated overdraft fee create issues for other consumer protection regulations and vice versa?
Do you have any guidance on what may be considered an appropriate automated overdraft fee whether it’s the initial fee or one for continuous overdraft?
Regulation E’s “Procedures for Resolving Errors,” along with that section’s Commentary, neither addresses nor prohibits banks from requiring helpful documentation such as police reports or signed and notarized affidavits. Are such actions are OK?
For those banks with an automated overdraft protection program, such as bounce protection, does a switch from a ledger-balance method to an available-balance method for the purpose of determining an assessment of an overdraft fee create any consumer issues?
Is the concept of “redlining” still an issue in 2017?