Week of Jan. 14

In This Issue…

• Sandy’s salutations
• ABA urges Trump, Congress to reopen government
• De novo bank formation: FDIC requesting information
• OBA looking for in-house bank counsel to serve on legislative review committee
• Is your bank helping federal employees during shutdown? Let us know!
• Register for OBA’s 2019 Contact Banker Program
• OBA education corner …

Sandy’s salutations

By Sandy Werner
OBA Chairperson

As I enter the last months as chair of the OBA, I can honestly say the opportunity has taken me places I never thought possible, and last night was no exception.

I was privileged to attend Gov. Stitt’s inaugural ball. You could feel the excitement throughout the venue as Stitt voiced once again his call to action that “Oklahoma’s turnaround starts now!”

Toby Keith was another highlight on the evening. Oklahoma is very blessed to have him; he is such a tremendous ambassador for our state.

On the federal side, however, the shutdown continues. Stitt has recommended financial institutions help customers who are experiencing hardship as a result of it. I know several banks, mine included, have already committed to waiving overdraft and non-sufficient fees for those impacted. Those with loans to impacted customers are also considering what they can do to help.

We want to hear from you. If your institution has come up with a way to help impacted customers, please send a quick email to Jeremy at jeremy@oba.com.

Together, we are the OBA!

——— Sandy

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ABA urges Trump, Congress to reopen government

Friday, ABA President and CEO Rob Nichols called on President Trump and Congressional Democrat leaders to reopen the government. He warned the shutdown has already begun to affect federal employees, consumers and the broader economy, and these effects are likely to worsen if the shutdown persists.

“Our member banks across the country report that the shutdown is starting to take a toll on local communities, preventing customers from securing mortgage approvals and small business loans, while threatening even more harm if the impasse continues,” Nichols said. “We call on all sides to work in good faith to end the shutdown for the good of the country.”

Also on Friday of last week, federal banking agencies issued a statement encouraging banks to work constructively with customers affected by the shutdown. “[P]rudent workout arrangements that are consistent with safe-and-sound lending practices” should not be subject to examiner criticism, the agencies said.

In addition, Monday the Oklahoma State Banking Department issued the following notice:

ASSISTING CUSTOMERS DURING THE
FEDERAL GOVERNMENT SHUTDOWN

At the recommendation of Governor Kevin Stitt, the Oklahoma State Banking Department encourages Oklahoma financial institutions to take practical measures to accommodate customers affected by the federal government shutdown. Institutions should consider measures consistent with safe-and-sound lending practices, taking into account the long-term interest of the institution and customers. We understand that accommodations may take the form of adjustments made to existing loans or the origination of new credit to support immediate cash flow needs.

We appreciate the financial community working with their customers during this shutdown. The Oklahoma State Banking Department will not criticize efforts taken by an institution under these circumstances.

“Thanks to (State Banking) Commissioner (Mick) Thompson for taking this very positive step,” OBA President and CEO Roger Beverage said. “Banks in Oklahoma have already begun implementing actions that offer assistance directly to customers affected by the shutdown. One of our officers’ banks just told us their bank ‘has already waived service/NSF fees and will consider the loan request side if we get any from our customers.’

“Another member bank is simply treating the bank’s customers who are adversely affected by the shutdown as if nothing has changed. This bank told me they know who their customers are and are ‘treating those customers as if they are getting their normal paychecks, with no NSF or other charges for now. When I heard that – and that’s the only bank I’ve heard from who’s responding to their customers in that manner – I thought it was really a remarkably good and positive step to help their customers weather the current shutdown storm. That’s the kind of thing that good community banks in Oklahoma do.”

Other banks have told us that they are offering interest-free payroll advances or other low-interest loans to their customers impacted by the shutdown. And others are making loan modifications and extending payment deadlines, depending on individual circumstances. Others are waiving fees for overdrafts and other kinds of fees.

“I have no idea how long this shutdown will go on,” Beverage said. “But I do know the leaders on both sides of the aisle are playing a very (politically) unpopular game of chicken. I just think people are seeing the ugly side of ‘politics’ and they’re tired of it. Unfortunately, it’s reinforcing the country’s negative attitude about the dysfunction of Beltway politics and how it’s being played today.”

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De novo bank formation: FDIC requesting information

This morning, the Federal Deposit Insurance Corporation released a “Request for Information” dealing with the de novo application process and seeking comments on all aspects of the process. In doing so, the Agency has asked 13 specific questions on which they are particularly focused. Comments are due Feb. 11.

“The questions are intended to help re-design the process of filing a de novo application while making it less cumbersome,” OBA President and CEO Roger Beverage said. “This effort is a part of Chairwoman (Jelena) McWilliams’ effort to make significant changes in the Agency and how it operates.”

Here are the questions the FDIC is asking you to consider:

1. What steps, if any, can the FDIC take to improve the de novo application process?
2. Are there any specific aspects or components of the application process that particularly discourage potential applicants from initiating or completing the application process?
3. Are there ways the FDIC could or should update or supplement existing resources to clarify expectations and promote a more transparent application process? If so, please provide details and support.
4. Are there any aspects of the pre-filing process, including with respect to the newly announced process regarding draft deposit insurance proposals, that could be modified or enhanced to further clarify expectations or processes for prospective applicants and improve applicants’ ability to submit a substantially complete application?
5. How effective is the application form and its related instructions? Could any elements of the form or instructions be modified or enhanced to improve applicants’ ability to submit a substantially complete application?
6. Are there any aspects of the field investigation process that could be improved to better facilitate completion of the application process?
7. In what ways could or should the FDIC modify the application process for proposed traditional community banks? How would any suggested changes impact the evaluation of the statutory factors?
8. In what ways could or should the FDIC modify the application process for proposed institutions that are not traditional community banks? How would any suggested changes impact the evaluation of the statutory factors?
9. Are there ways the FDIC could or should tailor its evaluation of applications from proposed institutions that are not traditional community banks, consistent with the statutory factors as described in the FDIC Statement of Policy on Applications for Deposit Insurance? If so, please explain.
10. Are there ways the FDIC could or should support the continuing evolution of emerging technology and fintech companies as part of its application review process? Are there particular risks associated with any such proposals, and, if so, are there ways such risks could or should be mitigated?
11. Are the FDIC’s expectations (as provided by the FDIC resources identified in this RFI) regarding capital adequacy and liquidity/funding for prospective applicants sufficiently clear and understandable? If not, what additional information or clarifications could the FDIC provide?
12. Are there legal, regulatory, economic, technological, or other factors separate from the application process that discourage potential applicants from submitting applications for deposit insurance that the FDIC should be aware of? If so, are there steps the FDIC could or should take to mitigate the impact of such factors?
13. Are there any other suggestions that the FDIC should consider for improving the effectiveness, efficiency, or transparency of the application process, or for addressing any other interests or concerns of stakeholders relative to the application process?

Let us know if you have questions or need/want additional information.

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OBA looking for in-house bank counsel for legislative review committee

The OBA is looking for in-house bank counsel to serve on and lend his or her services to a legislative review committee.

The committee will mainly operate January thru May, the same time period as the state legislative session.  The committee will review certain pieces of legislation to determine the impact it would have on day to day operations of a bank.

A majority of the correspondence will be done with conference calls or via email.  Please contact Adrian Beverage at adrian@oba.com if you are interested.

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Is your bank helping federal employees during shutdown? Let us know!

With the ongoing partial government shutdown, some Oklahomans have seen their income directly affected. We understand several Oklahoma banks have been working in positive and helpful ways with their customers and the OBA would like to get information to the media recognizing those banks.

If your bank has implemented a standard policy to help customers who are federal employees or others affected by the shutdown, or are helping on a case-by-case basis with those individuals, please let us know, and, if possible, just a few details on how, by dropping a quick email to jeremy@oba.com.

Thank you!

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Register for OBA’s 2019 Contact Banker Program

We have set the dates for the 2019 Contact Banker Program. Click here to find a sign-up form that has all the dates listed for this year’s program. We ask that you select what dates work best for you and send it your form to adrian@oba.com. Once we have the groups finalized, we will send an email confirmation of your date.

On the date that you select, there will be a short briefing before we start walking the halls of the state Capitol. Please know, we will stay together as a group the entire morning. We will do our best to have you spend a few minutes with both your state senator and state representative to either start a new relationship or strengthen one that is already in place. We won’t ask that you discuss the merits of current legislation, we want you to just chat with your member about issues that may affect your community or other pressing matters. Depending on what week you select, we will either sit in on a committee meeting or in the gallery to watch the action on the floor. Once we have finished all of our business at the Capitol, the OBA will take everyone to lunch to discuss the events of the morning.

This is our 19th year to have this program and all legislators know that there will be bankers at the Capitol on Tuesdays, and we always have legislators asking when their bankers are going to visit. Everyone at the Capitol knows the bankers are involved in the political process and they are watching how they vote. All of that success is because of the Contact Banker Program. This program is meant for all employees at the bank. There is no cost to attend other than your time.  

Please complete this registration form and send it to adrian@oba.com.

Should you have any questions please don’t hesitate to contact Adrian Beverage (adrian@oba.com / 405-424-5252).

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OBA education corner …

The dog days of winter are here. Wait … are there “dog days” in winter? If not, looking outside at the cold and gray makes on think there should be! One place you can stay warm is at OBA educational events – take note of the following:

• Basics of Real Estate Loan Documentation, Jan. 23, webinar — This webinar provides a comprehensive overview of essential real estate loan documentation requirements, regulatory compliance issues, sound loan administration issues and best practices.
• Health Savings Accounts, Jan. 23, webinar — Whether you are now offering HSAs or are thinking about offering HSAs, this two-hour, extremely informative webinar will give you the information you need to make sure you are setting the accounts up correctly and performing the proper maintenance and reporting.
• Accounting Essentials for Banks, Jan. 28, webinar — This webinar is designed to provide basic knowledge of how a bank records its financial transactions and compiles and communicates the information in its financial statements.
• Advertising Compliance, Jan. 30, webinar — Advertising is a unique situation for most banks in that several different regulations can all come into play for one, single ad.
• Dealing with Subpoenas, Summonses, Garnishments, Tax Levies, Etc., Jan. 31, webinar — On a daily basis, a financial institution is faced with having to comply with a multitude of legal documents that are served on it.
• 2019 Basic Personal  & Business Tax Return Seminar, Feb. 21, Oklahoma City — Attend this proactive seminar and gain an understanding of the often complex and confusing topic of TAXES!

Also, several scholarships are now available to bankers from OBA-member banks for various graduate schools of banking. Applications should be submitted to the OBA’s Janis Reeser by email (janis@oba.com), regular mail (643 N.E. 41st St., OKC, 73105) or fax (405-424-4518). The scholarship recipients will be selected and announced no later than April 22.

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