Friday, December 4, 2020

Week of April 9

In This Issue…

CRA changes recommended
Beneficial ownership FAQs
Board nominees selected for consideration by membership
OBA education corner …

CRA changes recommended

Since its enactment in 1977, the Community Reinvestment Act (CRA) has not been subjected to any type of updating to reflect the advancements and changes in the banking business. For one thing, the number of banking entities in the nation has dropped significantly, from some 20,000 entities when it was enacted to less than 5,500 today. Logic would suggest that the banking environment has significantly changed in the wake of that consolidation.

The Treasury Department recently issued its report of the Department’s analysis of the existing CRA rules. The Department is recommending a number of potential changes to the Community Reinvestment Act (CRA) rules. The report comes as the banking regulatory agencies are preparing to issue an advanced notice of proposed rulemaking that will begin the process of modernizing the CRA regulations, which have not been substantially updated since 1995.

The Treasury report focuses on four areas, including redefining geographic assessment areas, increasing transparency around the rating process, improving the examination process and incentivizing CRA performance. In addition, the report encourages the regulators to provide greater flexibility in the CRA process, particularly given significant changes in banking law and financial technology since the statute was enacted in 1977.

Click here to read more about the Treasury Report.

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Beneficial ownership rule FAQs

Last week FinCEN (Financial Crimes Enforcement Network) finally released an updated version of its Frequently Asked Questions (FAQ) outline in an effort to assist bankers as they prepare for the May 11 deadline. These expanded due diligence requirements are intended to find out who is really the controlling force of various businesses with which the bank does business, including corporations and limited liability companies.

“A lot of traditional community bankers may not be fully prepared for this new BSA/AML exercise,” OBA President Roger Beverage said. “Moreover, bank customers may not understand that it is the federal government that’s requesting this additional information, not the bank.”

There 37 new FAQs that are intended to build on an earlier set of FAQs issued two years ago. These new FAQs are an effort to address the many questions that have been raised by bankers in the wake of the rule’s adoption

“These additions try to clarify how you are to go about identifying the individuals in entities that have a very complex structure for business reasons,” Beverage said. “We’ve had a number of questions raised about what information you need in order to verify that the owners are who they say they are.

“We are working with the ABA and plan to make some video programs available to bankers, along with other materials that will help bankers explain the ‘whys’ to their customers,” he said. “My guess is there will be period for ‘ramping up’ before a full-throated examination takes place, but that’s all it is – a guess. We think additional information will be forthcoming shortly, and as soon as it’s released, we’ll make sure you have it available.”

Click here to read the 24-page guidance document.

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Board nominees selected for consideration by membership

Pursuant to Article V, Section 5.4 of the By Laws of the OBA, notice is hereby given of the slate of nominees that have been selected by each of Board’s nominating committees to serve a three-year term on the Board of Directors. The slate of nominees will be considered by the membership on May 22 at the annual meeting and convention of the OBA, to be held at the Hard Rock Hotel & Casino in Tulsa.

The Board consists of 25 members, 18 of which are elected for three-year terms, with three directors being elected from each of the OBA’s six geographic groups. Within each group, the terms of the Board members are staggered and they represent banks in the upper one-third of banks holding deposits in the Group, the middle one-third of banks holding deposits in the Group and the lower one-third of banks holding deposits in the Group. This year the nominees are for those Board seats representing the lower one-third of banks holding deposits within each group.

The nominees are as follows:

Group 1: Aaron D. Johnson, president, CEO and chief lending officer
The Farmers Bank, Carnegie

Group 2: David Cook, president and CEO
Bank of Laverne, Laverne

Group 3: Terri Thompson, president and CEO
American Exchange Bank, Henryetta

Group 4: Danny Seibel, president and CEO
First National Bank, Lindsay

Group 5: Priscilla Cude, president and CEO
First Bethany Bank & Trust, Bethany

Group 6: Mark Richey, president
Oklahoma Capital Bank, Tulsa

Pursuant to Section 6.3 of the By Laws of the Oklahoma Bankers Association, notice is hereby given of the nominee for the office of First Vice Chairman. The nominee was selected from among more than a dozen names that had been submitted to the Nominating Committee for consideration.

The nominee for the office of First Vice Chairman of the Oklahoma Bankers Association is:

Rick Walker, vice chairman & CEO
Liberty National Bank, Lawton

The members of the OBA will vote on who will become the next First Vice Chairman at the Annual Meeting of the Association for FY 2017-2018. That meeting will be held on Tuesday, May 22, 2018, at the Hard Rock Hotel and Casino Tulsa, 777 West Cherokee Street, Catoosa. The meeting will begin at approximately noon and nominations may be made from the floor.

If elected by the membership, Walker will succeed Frank “Frazier” Henke IV, president and CEO, American Bank and Trust, Tulsa, who will become vice chairman at the Convention. Walker will automatically become vice chairman at the FY 2018-2019 Annual Meeting and Convention and automatically will become chairman at the FY 2019-2020 Annual Meeting and Convention.

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OBA education corner …

Remember to stay current with everything that’s coming up on the Events Calendar at OBA.com, but also take note of the following:

  • Robbery Prevention & Response, April 18, webinar — Learn how to make your location more attractive to customers and less attractive to criminals.
  • Legal Issues of Checks, April 19, webinar — Understanding endorsements and handling checks is crucial to making sound check cashing decisions.
  • Basic New Accounts SeminarApril 24 – TulsaApril 25 – Oklahoma City — The biggest change to hit the new accounts desk since 2003 arrives May 11 – the new BENEFICIAL OWNER AND CUSTOMER DUE DILIGENCE RULE! But wait! Before we can add on something new, we need to absolutely nail down the basics and solidify our understanding of the new account principles, definitions, concepts that are with us always. So, we’ll do both at this seminar!
  • Creating the Right ERM Program for Your Community Bank, April 25, webinar — Learn the fundamental pieces of the ERM puzzle, how they relate to each other and how to integrate your ERM program into the bank’s strategic plan.
  • Safe Deposit Danger Zones, April 26, webinar — Recent safe deposit vault burglaries, devastating fires, tropical storms, damaging tornadoes, raging floods and many other nationwide disasters have significantly impacted our safe deposit industry.
  • Opening Minor Accounts, April 26, webinar — During this webinar, you will learn how to answer your adult account holders’ questions on how to set up accounts for grandchildren, for college and many other reasons to set up minor accounts.
  • HR Seminar, May 3, Oklahoma City — As we all know, human resource compliance is an ever-changing target. Knowing what to do in increasingly complicated HR situations can be difficult for even seasoned HR professionals.
  • Flood Compliance Seminar, May 2, Oklahoma City — The program is designed for compliance officers, operations personnel, mortgage loan officers, loan originators and others involved in obtaining and maintaining flood insurance on mortgage loans.
  • 2018 Compliance Roundtable, May 8, webinar — Join for lunch and open discussion with Mary Beth Guard and Pauli Loeffler.
  • Advanced Commercial Lending Series (register for all or separate days), May 9 – Advanced Financial Statements Analysis; May 10 – Advanced Tax Return Analysis; May 11 – C&I Real Estate Lending/Commercial Real Estate Lending — Commercial lenders, credit analysts, relationship managers and credit administrators would benefit from these programs.

Also, the OBA will be hosting women banking professionals for a morning at the state Capitol as part of its Women in Banking program. While there, we will hear from various elected officials regarding issues impacting our state. Click here for more information.

In additional news, now is the time to GET INVOLVED with your industry and your Association! The easiest and best way to do this is to join an OBA committee. There are several to choose from, ranging from school boards to agriculture and bank fraud. Click here to learn more about OBA committees and to download a Committee Interest Form!

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