Greetings from Guy
By Guy Sims
The White House was relatively quiet this past week: No berating the administration’s own attorney general, no red meat political speech to the Boy Scouts of America, relatively few early morning tweets and no major staff shake-ups. I would call this a calm week by President Trumps standards.
I have to think the new chief of staff, Gen. John Kelly, had something to do with this. Finally, and at long last, it now feels like there is an adult in the White House.
If the administration is ever going to advance its legislative agenda, including much-needed bank regulatory reform, it, in my view, will require more structure in the White House and a more responsible chain of command.
I get the feeling a focused agenda, a consistent message and fewer unneeded distractions (see previous early-morning tweets) would not be harmful to the president’s agenda! I think the appointment of Gen. Kelly is a good step in the right direction. Let’s hope the calm can last.
ABA Daily Newsbytes today reported the CFPB released four new “prototype” overdraft disclosure forms this Friday. (See article below). The CFPB is in the “pre-rule stage” of overdraft rulemaking per Director Cordray. I’m not sure what all of that means but I’m confident it’s not good for community banks.
We need to be proactive on this issue. Our upcoming Annual Washington Visit provides Oklahoma bankers the opportunity to meet directly with CFPB staff so they can explain how overdrafts work in the real world.
We’ll also have the chance to talk about why the proposed rules dealing with the requirements of Section 1071 of Dodd-Frank – requiring banks to collect HMDA-like data on small business loans. Both of these issues have the potential to have a significant impact on the income and expense side of your bank.
I encourage you to make plans now for the Annual Washington Visit on Oct. 1-3. Our time is now! Our voices need to be heard on these issues as well as the need to enact common sense regulatory and tax reform. I look forward to having you there the rest of us.
Friday, the Consumer Financial Protection Bureau let it be known it’s campaign of “Know Before You Owe” is pushing forward with the general subject of overdrafts. It released four new overdraft disclosure forms which are interesting and can be seen by clicking here.
Nothing official was released Friday – at least in terms of changes to what your bank does now. But, according to the American Bankers Association, “the bureau plans further testing of the forms to determine whether they are more effective than the model opt-in form that banks currently use to explain the overdraft protection options available to consumers.”
True to form, CFPB Director Cordray announced the Bureau “is currently in the ‘pre-rule stage’ of an overdraft rulemaking.”
“The Bureau seems to be obsessed with overdrafts, which they view as an extension of credit that ought to be subject to the rules associated with such loans,” OBA President and CEO Roger Beverage said. “You can probably bet that the new rules will be much more restrictive than we had hoped.
“What’s even more distressing to me, at least, is their ‘research’ was based on an analysis of consumers’ experiences with overdrafts at a number of large banks. It’s one more example of the government proposing to take action based on the assumption that ‘one-size-fits-all’ and these proposed rules should be applied to everyone. l just wish they would talk to some Oklahoma banks before they finalize whatever it is they have in mind. I’m pretty sure I won’t like it.”
For some interesting reading, click here for the CFPB’s report on frequent overdraft users
The OBA, through the University of Oklahoma Athletic Tickets Office, is offering our bankers an opportunity to purchase tickets to OU’s football season opener against UTEP on Sept. 2 for just $45 apiece.
You can purchase the tickets by going here and entering the promo code BANKERS, if prompted. Or, contact the OU Athletic Ticket Office at (405) 325-2469.
Same as kids currently preparing to go back to school for the year, bankers should be preparing to go back to school themselves with education opportunities from the OBA! Take a peek at the upcoming events:
- Annual Deposit Regulation Training for the Branch, Aug. 10, webinar — This regulatory review completes your financial institution’s annual training requirements.
- CRE Appraisals: Two Part Series, Part 1 – Aug. 14; Part 2 – Aug. 21, webinars — These give an overview of guidelines and issues critical to CRE appraisal.
- New Business Accounts: The Interview, CIP, New CDD, Aug. 15, webinar — This program will focus on building the process from different types of entities to different types of risk.
- Regulation O: Lending to Insiders, Aug. 15, webinar — This program provides the information needed by the lending, compliance and audit staff to assure ongoing compliance with the regulation.
- Same-Day ACH: Round Two, Aug. 16, webinar — We’ll review the rule, volume and who’s currently using Same-Day ACH.
- Applicants and Applications, Aug. 17, webinar — Join us for this two-hour applicants and applications compliance webinar. This webinar will cover the latest requirements and guidance.
- Flood Insurance: Compliance Issues and Enforcement, Aug. 22, webinar — We’ll concentrate on some of the more vexing issues in flood compliance by explaining best practices in keeping your portfolio covered.
- Opening Trust Accounts: Documenting Authority and Liability, Aug. 23, webinar — This webinar will cover standard trust-opening procedures and many questions that arise as trusts and account holder situations change.
- Call Report for Banks: Recent Changes, Highlights, Aug. 23, webinar — The webinar will cover the latest revisions and recently approved changes to the call report, as well as updates due to revisions in accounting standards.
- Dealing with Casual Days, Dress Codes and Work Appearance, Aug. 25, webinar — This program will cover the practical and legal issues and the current trends in workplace appearance and what you should and shouldn’t do about it.
- Cash Management, Aug. 29, webinar — During this two hour webinar, you will gain a more in-depth knowledge of cash management (a.k.a. Treasury Management) products and services.
- BSA/AML, Aug. 29, Tulsa — This program is designed to assist experienced personnel in staying ahead of BSA/AML compliance steamroller.
- BSA/AML, Aug. 30, Oklahoma City — This program is designed to assist experienced personnel in staying ahead of BSA/AML compliance steamroller.
- Reg E Seminar, Sept. 19, Oklahoma City — This program will provide a strong foundation in the requirements of Regulation E (Electronic Fund Transfers). We’ll address what’s covered and what’s not, the issuance of access devices, liability for unauthorized transactions, disclosure requirements, preauthorized transfers and error resolution.
- Analyzing Financial Statements, Sept. 20-22, Oklahoma City — Commercial lending officers, credit department personnel, loan review personnel and operations personnel interested in learning more about commercial lending will benefit from this three-day course.