Week of July 9

In This Issue…

2019 OBA convention set: save the dates!
Banks have questions on SQ 788/legalization of medical marijuana
Agencies grant S. 2155 stress-testing exemption to all institutions under $100 billion
CRA reform: We’re asking for your help, please!
Women In Banking conference scheduled for October
OBA education corner …

2019 OBA convention set: save the dates!

We’re happy to announce we’ve already set the dates and location for the 2019 OBA Annual Convention!

Mark your calendar for the OBA’s Annual Meeting and Convention to be held at

2019 OBA Annual Meeting and Convention
Hilton Garden Inn and Conference Center, Edmond
May 20-22, 2019

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Banks have questions on SQ 788/legalization of medical marijuana

As you might imagine, we’ve had a number of calls from bankers asking us what the passage of SQ 788 means for their business. Specifically, several have asked us what they can and cannot do with respect to “banking” anyone in or associated with a business that operates in the chain of ultimately getting marijuana to Oklahomans for medicinal purposes.

Our Association’s general counsel, Mary Beth Guard, will be putting on a program next month outlining what it’s all about. “Preliminary Considerations for Banking MRB’s” (MRBs – Marijuana Related Businesses) will be held in Oklahoma City and Tulsa as follows:

Tuesday, Aug. 7 — OBA’s Harris Event Center, Oklahoma City
Wednesday, Aug. 8 — Southern Hills Marriott, Tulsa
Registration 12:30-1 p.m.
Program 1-4 p.m.

Because there is no clear guidance whether you bank any aspect of the marijuana business, or reject those businesses, the OBA is also co-sponsoring another marijuana program with our colleagues in Colorado that is scheduled on Thursday, Aug. 9.

Banks in the 30 states that authorize the use of marijuana for medicinal or recreational purposes yearn for direction in this guidance-free zone. Banks that have opted not to accept marijuana deposits often unwittingly have them in the bank – to their surprise and their peril.

Banks need good risk management in this complex and shifting area. That requires good knowledge of the biggest threats and best practices. Importantly, banks in non-permissive states as well as banks in permissive ones need to ask, “Are we sure we’re not banking marijuana? If we are inadvertently, what do we do and what’s our risk?”

Here are the details:

Marijuana banking: Conflict of laws, banks in the middle

A National Conference* on Banking Marijuana & Hemp – Addressing:
• Banks opting to serve marijuana customers, and
• Banks wanting to keep marijuana business out of the bank

The conference has a limited number of seats and will allow open, candid discussions focused exclusively on banking; no MRBs can attend. Importantly, and in an effort to assure privacy in comments/questions, the program will not be recorded.

The sessions contained in this program are intended to serve various kinds of banks:

• Those opting to serve marijuana customers, and
• Banks wanting to keep marijuana business out of the bank, as well as
• Banks wanting to serve the hemp industry.

The conference is comprehensive – covering:

• Marijuana laws .
• Marijuana industry, products, employees, myths.
• Department of Justice and FinCEN views.
• Congressional status and outlook on federal law .
• FDIC, Federal Reserve, OCC and state regulators’ perspectives.
• Assessments by experienced bank legal counsel .
• Advice from bankers currently serving marijuana related businesses and those trying to avoid banking MRBs.
• Q&A and discussion sessions.
• Other relevant content including public image and reputation risk, insurance issues, hemp, alternative banking solutions that don’t work.


Location: Grand Hyatt Hotel
1750 Welton Street (east end of downtown Denver)

Room Reservations: Grand Hyatt room block COBA18

Registration: Thursday, 9-10 a.m.

Program: Thursday, 10 a.m.- 7 p.m.
Friday, 7:30 a.m.-Noon

Cost: $750

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Agencies grant S. 2155 stress-testing exemption to all institutions under $100 billion

Friday, the federal banking agencies issued a joint statement announcing company-run stress tests required under Dodd-Frank have been ended for banks with less than $100 billion in assets. This same exemption was applied to bank holding companies under $100 billion immediately upon passage of S. 2155. The exemption applies to every Oklahoma-based bank.

Click here to read the joint statement: https://www.occ.treas.gov/news-issuances/news-releases/2018/nr-ia-2018-69.html.

“[T]o avoid unnecessary burden for depository institutions and to maintain consistency between BHCs and depository institutions,” the banking agencies said that they would use their authority to delay the deadline for regulatory requirements connected to stress testing for banks and savings and loan holding companies with less than $100 billion in assets until Nov. 25, 2019. At that point, the 18-month period would have passed and statutory exemptions will be in effect.

“Today’s action will spare many banks from having to participate in stress tests that both regulators and banks have said provided little value and only distracted from more effective safety and soundness tools,” according to Rob Nichols, president of the American Bankers Association. “Instead of a one-size-fits-all approach, regulators are now bringing us closer to a program of tailored supervision in stress testing, which will allow banks to devote more of their time and resources to serving their customers and communities and helping grow the U.S. economy.” (emphasis added)

In a separate statement, the Federal Reserve announced it will not collect assessments from bank holding companies and savings and loan holding companies that hold less than $100 billion in assets for the year 2018 and forward. The Fed also said it will not require BHCs with less than $100 billion in assets to comply with certain regulatory requirements connected to enhanced prudential standards under Regulations Y, WW and YY.

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CRA reform: We’re asking for your help, please!

As you may know, federal banking regulators have been talking about making revisions to the way they approach compliance with the Community Reinvestment Act. What we’re asking of you is to take a very brief (one page) survey and tell us about the specifics for your bank and its efforts to meet its compliance requirements. The regulator would really like to hear from you about real-life examples about why the Act needs substantial revision.

Click here to take the short survey: https://aba.qualtrics.com/jfe/form/SV_88Ocg9Wj7u3gkG9.

The Comptroller of the Currency, Joseph Otting, has recently testified before the Senate Banking Committee about his priorities, beginning with CRA reform. We wish all federal banking regulators viewed the real world in this manner:

“As Comptroller, my short-term priorities have focused on initiatives to help banks promote job creation and economic opportunity while continuing to operate in a safe, sound, and fair manner. These priorities include modernizing the regulatory approach to the Community Reinvestment Act, encouraging banks to meet consumers’ short-term, small-dollar credit needs, enhancing our supervision of BSA/anti-money laundering compliance and making it more efficient, simplifying regulatory capital requirements and reducing burden associated with the Volcker Rule. At the same time, we continue to enhance the agency’s effectiveness and efficiency.”

Please. Take few minutes to let the federal regulators know your bank’s concerns and why CRA reform is so important. Identify real-world, actual problems with how CRA is administered today. You know they’re real problems, and the more banker concerns we can list, the better the chance at real reform.

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Women In Banking conference scheduled for October

Join the OBA in partnership with the Federal Reserve Bank of Kansas City and Community Bankers Association of Oklahoma for the second annual Banking and the Economy: A Forum for Women in Banking.

The Forum, set for Oct. 24 at the Embassy Suites in Norman, is designed to provide senior level and high potential middle management women bank leaders with industry, leadership and professional development knowledge that will enhance their careers and networks.

At #WomenInBankingOK, you will hear from top leaders in the banking industry about current economic conditions, banking, gender equity, FinTech, Tax Reform, and leadership strategies. Featured speakers include panelist Jill Castilla, president and CEO of the Citizens Bank of Edmond; Dr. Shirley Davis, president of SDS Global Services; Dionne King, CEO and strategic consultant of DMK Consults, LLC. and many more!

Don’t miss your chance to be part of this important conversation! Registration is $100. Please register soon, as previous conferences have sold out and space is limited.

If you know someone who would benefit from attending this conference, please feel free to share this invitation.

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OBA education corner …

Summer is upon us and the beach and mountains are calling many of our names! If, however, more work-related pursuits are your idea of taking advantage of these months of the calendar, the OBA has you covered! Take note of the following:

  • Providing Accurate and Timely Adverse Action Notices, July 16, webinar — Both the Equal Credit Opportunity Act (ECOA) and the Fair Credit Reporting Act (FCRA) contain requirements for providing notice of action taken. This webinar reviews the requirements of both laws and covers common violations and provides solutions.
  • Dealing with Subpoenas, Summonses, Garnishments, July 17, webinar — If you find these documents confusing and intimidating, attend this webinar to learn the best practices of how to deal effectively with these documents and the parties who serve them upon you.
  • Advanced Commercial Loan Documentation, July 18, webinar — Everything a commercial loan officer should know about the core commercial loan documentation package, including perfecting security interests on commercial collateral, loan agreements, signature requirements, loan closings and more.
  • Customer Due Diligence & Beneficial Owners: Two-Month Checkpoint, July 18, webinar — Gain help on formalizing and enhancing your due diligence program.
  • ACH Origination for Lenders and Cash Management, July 24, webinar — In this session we will explain why you need to be compliant with the ACH Rules and the ramifications if you are not.
  • Developing a Strong Enterprise-Wide Risk Assessment for Your ERM Program, July 24, webinar — This webinar will take you through a step-by-step process to develop Risk Assessments to address key areas of your institution.
  • Audit Report Writing, July 26, webinar — This highly specialized webinar offers a deep and useful toolbox of techniques that auditors can use when noting audit observations, drafting objective work papers, and composing well-structured, detailed and fluent audit reports.
  • New SAR Line By Line, July 26, webinar — FinCEN has issued a notice to e-filers that announces an update to the Suspicious Activity Report filing format, to go live in June 2018. This webinar will help.
  • Lending to Churches & Other Religious Institutions, July 27, webinar — This course will cover the major church lending risks and discusses how a bank can prudently manage these risks by exposing participants to the appropriate methods of analyzing and lending to religious organizations.
  • 2018 OBA Compliance School, Aug. 27-31, Oklahoma City — This school is designed to provide an extensive body of knowledge and information on consumer compliance that can contribute to the development of compliance officers and to their associated functions, both of which have become an integral and essential part of our evolutionary banking industry.

Also, as mentioned in the first story of this Update, make sure to SAVE THE DATE for the OBA’s initial seminars addressing bankers concerns over the recent legalization of medical marijuana. “Preliminary Considerations for Banking Marijuana-Related Businesses” will take place on Aug. 7 in Oklahoma City and Aug. 8 in Tulsa.

There is much that is not yet known, but you can begin to evaluate the risks and rewards and compliance obligations of providing services to marijuana-related businesses (or find out how to steer clear of doing so). Attend this seminar to get up to speed on what we know now.

More registration information will be following within the next week. Contact the OBA for any information!

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