Week of Feb. 19

February 20, 2018

In This Issue…

• Waiting on McConnell
• CFPB releases strategic plan; requests public comments on supervisory process
• Nominee process for OBA Board positions
• OBA Bankers’ Night Out programs ready for spring
• OBA education corner …

Waiting on McConnell

It’s frustrating for us to keep reporting the same news about regulatory reform for community banks – nothing is happening. It’s like Groundhog Day, the movie.

We’re told the Senate Majority Leader, Sen. Mitch McConnell (R-Ky.) has “promised” to put this bill (H.R. 2155) on the Senate floor “soon.” Great. What does “soon” mean? We have not a clue.

The House remains active, and has passed a number of bills that are good steps forward for community banks. The problem is none of them will be voted on in the Senate this Congress (which expires next January).

Here are some examples, all of which would be good news:

R. 1153: Clarifies points and fees test under QM rules;
R. 3978 deals with TILA-RESPA integrated disclosures. It changes an existing CFPB-implemented rule that does not allow disclosure of title insurance premiums and any potentially available discounts to home buyers. And this bill would permit their disclosure. The CFPB’s rule creates inconsistencies in mortgage documents and creates confusion for consumers.
R. 3299 addresses a rule by the Court of Appeals for the 2^nd Circuit dealing with choice of law issues. This proposal clarifies that mortgages that are valid when made under the originating state’s law. It’s the Madden v. Midland Funding decision.
Moreover, this rule would remain valid even if the bank sold or assigned the loan to a third-party. It was this circumstance in the Madison case that threw everything into a confused mess. The bill would codify the “valid-when-made” doctrine.
R. 4771: Requires the Fed to revise its Small Bank Holding Company Policy Statement on Assessment of Financial and Managerial Factors so that banks that must meet this standard must now be >$3 billion, up from $1 billion.

CFPB releases strategic plan; requests public comments on supervisory process

From the American Bankers Association: Acting Director Mick Mulvaney recently released the CFPB’s strategic plan for 2018-22. The plan identifies three goals for the Bureau:

Ensuring that all consumers have access to markets for consumer financial products and services.
Implementing and enforcing the law consistently to ensure that markets for consumer financial products and services are fair, transparent, and competitive.
Ensuring “operational excellence.”

To meet these goals, the CFPB will provide information and education to consumers; “regularly identify” outdated, burdensome or unnecessary regulations; and ensure transparent and efficient financial market operation. In addition, the Bureau intends to continue enforcing UDAAP and discrimination laws.

In related news, the Bureau also recently issued a request for information asking for feedback on its supervision processes. Specifically, the RFI asks for comments on

The efficiency and effectiveness of the supervision program and whether any changes to the program would be appropriate.
The timing, frequency and scope of supervisory exams, the Bureau’s information collection requests, the exam manual, the effectiveness of onsite exam work, exam communications including supervisory letters and exam reports, the clarity of matters requiring attention and the appeals process, among other things.
Comments are due 90 days after publication in the Federal Register.

Nominee process for OBA board positions

Pursuant to the By Laws of the Oklahoma Bankers Association, notice is hereby given of the names of each of the six Board nominating committees. Each of these committees will select a banker from that group to serve a three-year term on the OBA’s Board.

The Board structure includes 18 directors elected from each of the six OBA Groups for a three-year term. One of these directors must be from a bank that is in the lower one-third of deposits within that group; another must be from a bank in the middle one-third of deposits within that group; and the third director must be from a bank that is in the upper one-third of deposits within that Group. This year the Board seats that are rolling off are representatives of banks in the lower one-third of deposits within each of the six groups.

Anyone interested in being a candidate for the OBA Board should notify any of the Committee members within the Group, or call, text or email Roger Beverage at the OBA.

Click here for the contact information for each of the committees. Highlighted names on the list serve as chairman of each committee and are the outgoing Board members:

The Nominating Committee for the Office of First Vice Chairman will be announced as soon as the Board confirms the Chairman’s selections. The Committee is chaired by Immediate Past President Curtis Davidson.

Contact Roger Beverage at the OBA for questions, suggestions:

roger@oba.com
405-424-5252
405-850-0695 – Cell/text
643 NE 41^st Street
OKC 73105

OBA Bankers’ Night Out programs ready for spring

The dates for the OBA Bankers’ Night Out programs have been finalized. Mark your calendar for the date of the program that’s in your area of the state and plan to attend. Bring your coworkers with you so that everyone can be up to speed on the most recent developments affecting their job.

As in the past, the schedule for each of these meetings is:

5:30 p.m. – Drinks
6:15 p.m. – Program
7 p.m. – Dinner

PRE-REGISTRATION IS REQUIRED. The cost is $40 per person. Click here for a registration form.

Locations and dates for this year’s events are:

Krebs, March 13.
Lawton, March 15.
Enid, March 27.
Oklahoma City, March 28.
Tulsa, April 3.
Guymon, April 19.

OBA education corner …

A new website and new-look online registration belies the fact the OBA is still offering the same thing as it was before: top-notch continuing education for our member bankers!

Remember to stay current will everything that’s coming up on the Events Calendar at OBA.com. But also take particular note of the following, particularly the TRID Rules programs, as they are coming up soon and provide MUCH up-to-date information needed by our bankers:

- Ransomware and Cyber Extortion, Feb. 22, webinar — Join us to recap the statistics related to ransomware and learn how to prepare for this growing threat.
- Dealing with Appraisals: Regulations and Requirements, Feb. 23, webinar — Learn in-depth details of the appraisal and valuation process, from both the lender and appraiser side of the game.
- Implementing the Updated TRID Rules, Feb. 27 – Tulsa; Feb. 28 – Oklahoma City — This one-day program reviews the 2017 amendments and explains how the amendments impact the existing rule.
- ACH Origination and Same-Day Entries, Feb. 28, webinar — In this session, we are going to review the general origination warranties and then review the most used Standard Entry Class Codes. We’ll look at the authorization requirements, format and specific warranties for those SEC Codes. We will also discuss the new Same-Day ACH and how your origination business may change with this option.
- Basic Bankruptcy for Bankers, March 1, webinar — This webinar will introduce you to the world of bankruptcy. It is designed for lenders and support staff with the goal of educating them on the fundamentals of both consumer and commercial bankruptcy law. Practical information for daily use will be provided.
- Basic Tax Return, March 1 – Tulsa; March 2 – Oklahoma City — Attend this proactive seminar and gain an understanding of the often complex and confusing topic of taxes!
- Commercial Construction Lending, March 5, webinar — This program provides an overview of the key steps involved in effectively administering commercial construction loans.
- How to Analyze a Start-Up Business, March 8, webinar — This program will use business plans and the information contained within them to demonstrate to lenders the ways in which they can analyze start-up ventures in order to make better credit decisions.

Also, the OBA is proud to promote the recognition of bankers who have devoted 50 or more years of service to the banking industry. All eligible nominees will be honored at the 2017 OBA Convention on May 24 at the Embassy Suites in Norman.

Click here to download a nomination form. If you have any questions, please contact Janis Reeser at 405-424-5252 or janis@oba.com.

One final quick note: Save the date for this year’s OBA Women in Banking Conference, set for Oct. 24 at the Embassy Suites in Norman. More information, along with registration materials, will be available in the coming months!