Monday, October 14, 2019

Week of June 11

In This Issue…

FDIC issues FIL on weather-related guidance

Monday, the Federal Deposit Insurance Corporation published a “Financial Institution Letter” in which it announced a series of steps intended to provide regulatory relief to financial institutions and facilitate recovery in areas of Oklahoma affected by severe winter storms, straight-line winds and tornadoes. This guidance applies to all financial institutions with total assets less than $1 billion.

The affected areas in Oklahoma are Muskogee, Tulsa, and Wagoner counties.

You can click here to read the FIL.

Highlights of the guidance include:

  • Lending: Prudent efforts to adjust or alter terms on existing loans in affected areas should not be subject to examiner criticism. In supervising institutions affected by the severe weather, the FDIC will consider the unusual circumstances they face. The FDIC recognizes that efforts to work with borrowers in communities under stress can be consistent with safe-and-sound banking practices as well as in the public interest.
  • Community Reinvestment Act Credit: The kinds of credit and other activities that should be taken into account include community development loans, investments, or services that revitalize or stabilize federally designated disaster areas.
  • Investments: Bankers should monitor municipal securities and loans affected by the severe weather. Appropriate monitoring and prudent efforts to stabilize such investments are encouraged.
  • Reporting requirements: If you expect delays in filing your bank’s call report, or other required documents, notify the Dallas Regional Office right away. The FDIC will evaluate any causes beyond the control of a reporting institution when considering the length of an acceptable delay.
  • Publishing requirements: Banks experiencing disaster-related difficulties in complying with any publishing or other requirements should contact the Dallas Regional Office.
  • Consumer laws: For consumers’ principal dwelling-secured loans, Regulation Z provides consumers an option to waive or modify the three-day rescission period when a “bona fide personal financial emergency” exists. To exercise this option, the consumer must provide the lender with a statement describing the emergency in accordance with the regulation.
  • Temporary banking facilities: The Dallas Regional Office will expedite any request to operate temporary banking facilities by an institution whose offices have been damaged or that desires to provide more convenient availability of services to those affected by severe weather. In most cases, a telephone notice to the FDIC will suffice initially. Necessary written notification can be submitted later.

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OBA brings back Compensation Survey

The OBA is partnering with Blanchard Consulting Group to offer the 2019 Salary and Cash Compensation Survey, with specific reporting on Oklahoma banks.

This survey focuses on gathering salary and cash compensation (salary plus annual cash incentive/bonus) data for approximately 20 executive positions and over 100 middle management and staff level positions. In addition, the survey provides information on actual bonuses paid (as a percent of salary) as well as the earning opportunity level positions eligible to earn under a performance-based cash incentive plan. Under this new format, position descriptions for lending include guidelines related to portfolio size to better clarify the classification and, ultimately, utilization of report data.

This data can be used by human resource professionals to assist in assessing the competitiveness of base salary for most positions in your bank, developing or managing salary grades, and making salary increase decisions. In addition, this survey provides information on the amount of annual cash incentive/bonus amounts paid to all positions throughout the bank. Data cuts will be broken out by asset size and region (coast, non-coast and Oklahoma) when we have a large enough sample size.

Below is the pricing for the 2019 Salary and Cash Compensation Survey results (survey findings will be provided via email in PDF format):

  • OBA Member & Participant: $300.
  • OBA Member & Non-Participant: $600.
  • Non-OBA Member & Non-Participant: $800.

To complete the survey, please click on the link below. Download the excel file and email the completed survey to surveys@blanchardc.com by June 21. 

2019 Salary and Cash Compensation Survey Link (OK)

If you would like to pre-order your copy of the survey or if you have any survey questions, please contact Laura Roth at surveys@blanchardc.com or 612-886-1225.

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Oklahoma Bankers Hall of Fame taking nominations

The Oklahoma Bankers Hall of Fame has been created by the OBA Board of Directors to honor individual bankers for their contributions to the banking industry and the State of Oklahoma.
In addition, the Hall of Fame is intended to recognize bankers’ achievements on behalf of the Association’s member banks.

Bankers make a difference in their communities every day. To rise to the level required for induction into the Hall of Fame, the nominating committee for the Hall will examine whether the individual banker has made a difference beyond their local community. The Hall of Fame will also preserve the unique history of Oklahoma’s banking greats.

The following criteria will be considered by the nominating committee when selecting individuals to be nominated for selection to the Hall of Fame:

  • Affiliation (past or present) with an Association member bank.
  • Service on boards or committees of the Association.
  • Participation in the activities of banker trade associations at the national level, such as the American Bankers Association and Independent Community Bankers of America.
  • Contributions to the development, improvement and growth of the banking industry in Oklahoma.
    Whether the individual has had a significant impact on the manner in which financial services are provided to consumers.
  • The individual has demonstrated the importance of community involvement and participation in the work of various community groups at the local, state and national levels.
  • The number of years of service to the state and the industry.

Nominations for induction into the Oklahoma Bankers Hall of Fame may be made by any bank employee of an OBA-member bank. There is no limit on the number of nominees that can be presented to the nominating committee in any given year.

Nominees may be either living or deceased.

Nomination forms are available by clicking here and can also be obtained by calling the Association (405-424-5252) or emailing info@oba.com.  Anyone who was on the ballot previously but not elected will automatically be included with applications received this year for ballot selection by the Nominating Committee.  They don’t need to do anything but are welcome to ‘update’ their application if they’d like. The application and other helpful information are available on our website.

Note: The deadline for receipt of applications is June 28, 2019.

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House to consider NFIP reauthorization, beneficial ownership bills

Late last week, House Financial Services Committee Chairwoman Maxine Waters (D-Calif.) and Ranking Member Patrick McHenry (R-N.C.) announced they have reached agreement on extending the National Flood Insurance Program through Sept. 30, 2024. The bill will also include a series of reforms addressing affordability issues, developing an improved flood mapping program, improve floodplain management and mitigation to the program’s operations.

NFIP reauthorization is on a fast-track and will be marked up later today by the House Financial Services Committee. Another bill scheduled for mark-up today was introduced by Rep. Carolyn Maloney (D-N.Y.). If approved, this bill will create a secure, national registry of legal entities like LLC’s and partnerships, the ownership of which is difficult to obtain. This new registry will be overseen by FinCEN. The committee will also hold a hearing on the student loan servicing market.

“This reauthorization agreement is a big deal,” OBA President and CEO Roger Beverage said. “We’ve been doing what we can to help ABA and some of our brothers and sisters in other states who have also been busting their tails to get this long-term reauthorization through the Congress.

“We’re not there yet. But this gives us one less hurdle to clear, IF the Committee agrees with the purposes of the bill. And there’s also a new provision that provides ‘continuous coverage’ for borrowers who leave the national program to buy private flood insurance and later return to the national program.”

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Annual Washington Visit scheduled

The OBA’s Annual Washington Visit has been scheduled for Sept. 15-17, 2019, and the hotel will be the Trump International Hotel Washington D.C.

Additionally, NEW this year, we are offering an offsite excursion to Mount Vernon that will include transportation, private tour (of the historic area, mansion & tomb), lunch and free time to explore the grounds.

Registration information should be hitting your bank shortly, but you can also download the registration and information form, and get more info on the hotel, by clicking here.

If you have any questions, contact Adrian Beverage or Megan McGuire at the OBA.

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OBA education corner …

It’s not the heat right now, it’s the humidity. Of course, just give it a couple of more weeks and then it’ll be the heat, too! Avoid having your hair frizz and stay indoors and catch one of the upcoming OBA webinars in the comfort of your office or home!

Take note of the following events:

  • Quarterly Compliance Briefing, June 18, webinar — The presentation will include a quarterly update that will address new items to be aware of, deadlines and what’s on the horizon.
  • HDMA Advanced Lessons, June 20, webinar — A two-hour webinar devoted to the more complicated areas associated with HMDA data collection and reporting. This is not an HMDA 101 class! It will provide understanding into the data fields that are giving banks the most headaches and help navigate a path to a higher level of HMDA understanding.
  • Three Key Risk Assessments in ERM, June 20, webinar — This webinar will first take you through a basic review of what is ERM and the basic steps to develop strong Risk Assessments to address key areas of your institution. Then will specifically focus on three key Risk Assessments you must have as critical components of your ERM Program.
  • Residential Construction Lending, June 21, webinar — This presentation will examine the characteristics and risks inherent with these borrowers; how to underwrite them and the real estate project under construction.
  • Signature Card Danger Zones, June 25, webinar — This webinar is a cost-effective way to train those who open new accounts on the potential liability of signature cards that are improperly set up.
  • Common Pitfalls of ARM Disclosures, June 26, webinar —  This two-hour program explains how to avoid problems when developing, maintaining and auditing ARM disclosures.
  • Do’s and Don’t on Checks, June 26, webinar — Learn the safe way to handle checks and be sure that you and your financial institution can be protected from loss on the negotiable instruments.
  • Records Management and Retention, June 27, webinar — Records management is the point of convergence of several resources, which is why effective and reliable records management must be part of your compliance program.
  • Role of the Information Security Officer, June 28, webinar — When it comes to information and cyber security the responsibility falls at several levels including the board of directors and senior management.

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