Community Bankers for Compliance Program
Fall Live Regulatory Seminar
Date: October 2-3, 2019
Ramkota Hotel & Conference Center, 800 S 3rd St Bismarck ND
Day 1: Unfair and Deceptive Acts or Abusive Practices / Advertising
“I have a question – I just saw an advertisement for a new product that our bank is offering, and I think this part of the ad…”
Unfortunately, CBC members have had to make that kind of hotline call. We solicited suggestions regarding areas in which compliance officers were struggling. Advertising was on the list several times, and since a great many of the advertising questions might have a UDAAP component (usually driven by competitive issues), we are going to discuss these subjects together.
We will begin with a discussion of the actual UDAAP requirements, then move on to the requirements of Regulation DD (deposits) and Regulation Z (loans) regarding advertising. After completing that discussion, we will focus on real life applications – based on our company’s audit findings in various institutions, other resources, and our company’s experiences in this area. Be prepared to share opinions in a group setting.
Included in the discussion will be sample advertisements or radio scripts which may or may not contain regulatory or UDAAP issues – you will be the judge. And after all, that is part of the issue. The regulations are fairly clear, but UDAAP is in the eye of the beholder (think regulator or plaintiff’s attorney). We hope that this discussion helps you avoid issues with either group.
Who Should Attend
Compliance Officers and Auditors should attend this session. In addition, all personnel with responsibilities for marketing and advertising will find this session useful, including senior management and others.
AGENDA - DAY 1
Unfair Acts or Practices
Deceptive Acts or Practices
Abusive Acts or Practices
Relationship to Other Laws
A review of the appropriate sections of Regulation DD.
A review of the appropriate sections of closed end Regulation Z.
Case Studies, Advertisements, Radio
A sampling of each – some will be fine, some wrong, some UDAAP – you be the judge
Day 2: Policies / APRWIN / Responding to Audit Findings / Lending Errors
Our presentation will begin with a discussion and a listing of compliance related policies that a bank should consider having, and those that banks are required to have. We will discuss the regulations involved, the general regulatory requirements, policy issues that should be included, and similar information. This was a suggestion made by CBC members last fall, and, as promised last quarter, we will cover it in this session.
The balance of the day also was suggested by CBC members. It will involve real world compliance situations. “The examiners/auditors/consultants found a violation. What do we do now?” Included will be consumer loans, mortgage loans, construction loans, and HELOCs. As part of the presentation, we will discuss how to use APRWIN to avoid some errors in the first place, and to correct errors, when that becomes necessary.
As the basis for the errors that will be discussed, we will focus on issues that regulators have mentioned in their various publications over the last couple of years. Other errors will be based on audit findings we have seen in various institutions, our audit findings over the years, hotline questions, and other sources. Drawing on these multiple sources will allow the case studies to be relevant to all attendees.
We will begin with a discussion of the basics of APRWIN. We will discuss errors that involve finance charge and APR issues, but our discussion will include many other errors as well. We will discuss other Regulation Z errors, TRID errors, flood errors, RESPA errors, and other errors that can or have occurred. We will not be discussing Regulation B errors – that is a subject for another time. Be prepared to share ideas and/or opinions in a group setting.
Who Should Attend
Compliance Officers and Auditors should attend this session. In addition, all personnel with responsibilities
for consumer, mortgage, or HELOC lending will find this session useful, including senior management and
AGENDA - DAY 2
Regulations that are a part of our world
Policies you should or must have
Real world issues
Using APRWIN for all closed end consumer loan types
Audit Findings / Lending Errors
A series of case studies to discuss the audit finding, the required actions, and how to respond to the audit finding after the “repair” (if there is one available) is complete. Consumer, Mortgage, HELOC, and Construction loans will be included.
ICBND and Community Bankers for Compliance (CBC) Members: If 2019 annual dues of $1,500 for one attendee or $1,800 for two attendees has been paid, no additional cost for this session.
$200 per 2-day session for each additional attendee above 2 attendees.
ICBND Members who are not members of the CBC Program $950 per 2-day session for the first attendee.
$600 per 2-day session for each additional person.
$1,400 per 2-day session for the first attendee.
$1,000 per 2-day session for each additional attendee.
Registration on Day 1 of each 2-day seminar will be at 9:30AM and the session will run from 10:00 AM-4:30 PM. Day 2 will run from 8:30 AM-3:00 PM.
15 days or more prior to seminar date, you will receive a full refund of the registration fee; 8-14 days prior to seminar date, you will receive a 50% refund; and 0-7 days prior to seminar date, there will be no refund given.