Community Bankers for Compliance Annual Membership
The Independent Community Banks of North Dakota (ICBND) is pleased to once again provide the annual Community Bankers for Compliance (CBC) Program. The CBC Program is the most successful and longest running compliance training program in the country.
The CBC Program provides your bank with up-to-date information on the ever-changing bank regulations, as well as guidance for structuring and maintaining your in-bank compliance program. In addition, it provides a forum where those responsible for regulatory compliance can discuss issues and exchange ideas with other community bankers.
Membership to the CBC Program consists of the following:
Live Regulatory Seminars – The live seminar topics are selected based on the most recent industry and regulatory developments, which may have an impact on community banks. Each person attending the program will receive a detailed manual written in full narrative, that they can take back to the bank as a reference and training tool. The seminars are provided twice during the year.
Regulatory UpdateWebinars - Four regulatory update webinars will be offered through the year. Each webinar will discuss current news and regulatory changes that may have an impact on community banks at each session.
Monthly Newsletter - The Compliance Update newsletter is sent to program members each month. It provides an update of compliance issues that impact community banks.
Compliance Hotline - Members of the program may call the Young & Associates’ toll-free number, or visit their website (www.younginc.com), for compliance questions that arise on a daily basis. Young& Associates has many qualified professionals available to answer your questions. This service ensures that your bank is just a phone call away from the information you need in order to answer your compliance questions.
CBC Members Only Web Page - This web page is reserved for banks that are registered members of the CBC Program. In it you will find special and timely information, as well as tools provided by Young & Associates, Inc., that can be used to enhance the regulatory compliance function at your bank.
Program Flexibility - To assure CBC members are getting the most out of their memberships,this program is designed with flexibility in mind. We realize that responsibilities change quite frequently within some banks. For this reason, membership is granted to banks, not individual bank employees. This enables you to send your bank’s compliance officer, as well as additional representatives as the topics apply to the various areas of the bank. By sending these representatives to the sessions that matter most to them, you are greatly enhancing the bank’s ability to implement compliance throughout the bank.
Who Should Attend? - The focus of CBC is always regulatory compliance. It is essential that your bank’s compliance officer attend. However, because regulatory compliance should be approached from a team perspective, many banks find it extremely beneficial to send additional employees to sessions on topics that relate directly to their positions in the bank. These employees typically come from the customer service, lending, or operations departments in the bank. To support this team effort, the CBC has been priced to enable your bank to send additional employees at a substantial savings.
Consent for Use of Photographic Images – Registration and attendance at, or participation in, ICBND meetings and other activities constitutes an agreement by the registrant to ICBND’s use and distribution (both now and in the future) of the registrant’s or attendee’s image or voice in social media, photographs, videotapes, electronic reproductions, and audiotapes of such events and activities.
Community Bankers for Compliance Program
2022 Dates and Locations
Contact Jessie Pfaff for more information and to register. firstname.lastname@example.org
April 19-20, 2022 Spring Regulatory 2 Day Seminar - LIVE
Location: Holiday Inn Bismarck, 3903 State Street, Bismarck ND 58503 701.751.8240 - ICBND room block rate of $99/night plus tax
Day 1: 9:30 am registration / Session 10:00 am - 4:30 pm
Day 2: 8:30 am - 2:00 pm
***All times are Central Time***
Sessions & Agenda
Day 1: Finance Charge and FFIEC APR Loan Calculator - Reviewing Closed End Loan Advertising
We will be covering 2 distinct subjects during day 1.
The first subject will be finance charges and the FFIEC Loan APR Calculator. First, we will discuss the calculation of prepaid finance charge (PPFC), as any PPFC error creates APR errors and potential restitution. While we will discuss the finance charge text from Regulation Z, our primary focus will be on the more recent consumer and mortgage loan fees that Regulation Z does not directly address, to determine whether they may be PPFC. We will then apply that knowledge and discuss numerous examples of all the different possible loan types that the FFIEC software can handle, examining loans that are correct and loans where restitution may be required. Attendees are encouraged to have a device available that will allow access to the FFIEC program. By doing so, the attendees can input the keystrokes that will be shown to get that “hands-on” understanding of how the software actually works.
The second portion of day 1 will be reviewing closed end loan advertising. We will briefly examine the regulatory text. Then we will discuss the requirements of a closed end loan compliance advertising review. This will be followed by a review of the advertising text for various closed end products, and attendees will be given the “hands on” opportunity to review the advertisements prior to our discussion. An advertising checklist will be provided as part of this portion of the presentation. The focus will be on the role of the compliance officer in reviewing the advertisement, and to offer concrete suggestions to avoid just saying “no” to the efforts of the marketing department. While marketing personnel are welcome, the focus is not on marketing, but compliance.
Unlike our standard CBC presentation, day 1 will be focused on hands on activities rather than simply a review of the regulation.Future
Day 2: October 1, 2022 Qualified Mortgage Regulation - HPML Mortgage Loans - HOEPA Mortgage Loans - Military Lending Act
For day 2, while we have been hesitant to discuss the new qualified mortgage rule in the CBC, as we thought it might change, the CFPB has recently issued new information regarding qualified mortgages and ARM loans, which leads us to believe that the qualified mortgage rule will change on October 1, 2022, as scheduled. The APR impacts qualified mortgages directly, and also impacts the other topics in the presentation.
Qualified Mortgages: The first subject will be the new qualified mortgage rule, which is fairly simple, but does have some issues that we will need to address for certain loan types. As with all the other topics in the presentation, the APR is the factor that will determine whether you have a qualified mortgage.
Higher Priced Mortgage Loans (HPML): The second subject will be HPMLs. This portion of the regulation contains a very similar calculation that will be used for qualified mortgages beginning October 1, 2022. HPMLs represent approximately 10% of the loans that are made across the country, based on HMDA data, and many of the HPML loans are adjustable-rate mortgages – but not all of them. As pricing becomes more critical based on our current economic situation, HPMLs may become more prevalent. We will review both the calculation and the impacts that HPML loans will have on the bank and the customer – including escrow and appraisals.
High-Cost Loans (HOEPA): The acronym HOEPA is for the Home Owner Equity Protection Act. Once again, a calculation similar to the qualified mortgage calculation is used to determine whether you have an HOEPA loan. While there are very few loans that meets the HOEPA standard, a HOEPA loan causes significant difficulties for your institution -once again including escrow, appraisals, as well as other issues such as mandatory home ownership counseling.
Military Lending Act (MLA): The last subject of the day will be the Military Lending Act. Like the other three topics, the APR - and most especially the Military APR - determines whether you have an issue under the MLA. We will discuss the implications of exceeding the Military APR on an MLA related loan. We should note that some MLA related loans are not mortgages.
Who Should Attend?
Compliance officers, lending management, lenders and processors, and any others with responsibilities for lending should attend. Additionally, audit personnel will find this session useful.
Dale Neiss, CRCM, Consultant, Young & Associates
With over 30 years of banking experience, Dale Neiss provides consulting and training, and writes articles and compliance manuals for Young & Associates. He has developed and implemented compliance management systems, loan review and community reinvestment act (CRA) programs, and enterprise risk management (ERM) framework for multiple banks. He has held the titles of Compliance and Loan Review Manager, BSA and CRA Officer, and Enterprise Risk Management Director. Dale began his banking career with the Office of the Comptroller of the Currency in Indianapolis, IN as an associate national bank examiner. He holds the designation of Certified Regulatory Compliance Manager (CRCM).
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About the Young & Associates, Inc. Instructors for the CBC Program
Bill Elliott, CRCM, Director of Compliance Education
Bill Elliott has over 40 years of banking experience. At Young & Associates, he leads compliance seminars, conducts compliance reviews for all areas of compliance, conducts in-house training, and writes compliance articles and training materials. During his career, Bill spent 15 years as a compliance officer and CRA officer in a large community bank and worked for a large regional bank. He has been a lender for consumer, commercial, and mortgage loans, and has manageda variety of bank departments, including loan review, consumer/commercial loan processing, mortgage loan processing, loan administration, credit administration, collections, and commercial loan workout. He holds the designation of CRCM.
Sharon Bond, CRCM, Consultant
Sharon Bond specializes in consumer compliance at Young & Associates. She leads compliance seminars, conducts compliance reviews for all areas of compliance, conducts in-house training, and writes compliance articles and training materials. With over 30 years of industry experience, she has a strong background in mortgage lending and federal consumer compliance laws and regulations. Sharonwas an Associate National Bank Examiner with the Office of the Comptroller of the Currency for five years. In addition to her CRCM designation, she holds the designation of the Six Sigma Qualtec Black Belt certifications.
Dale Neiss, CRCM, Consultant
With over 30 years of banking experience, Dale Neiss provides consulting and training, and writes articles and compliance manuals for Young & Associates. He has developed and implemented compliance management systems, loan review and community reinvestment act (CRA) programs, and enterprise risk management (ERM) framework for multiple banks. He has held the titles of Compliance and Loan Review Manager, BSA and CRA Officer, and Enterprise Risk Management Director. Dale began his banking career with the Office of the Comptroller of the Currency in Indianapolis, IN, as an associate national bankexaminer. He holds the designation of CRCM.
Subjects for future seminars will be shaped by regulatory events as they unfold. The CBC quarterly compliance program remains committed to providing as much up-to-the- minute information as possible. The program will closely monitor releases from the CFPB and other agencies to assure that you have the most up-to-date and accurate information possible.
For more information on CBC Membership call Jessie Pfaff at 701.258.7121.