Appraisals Process

Join the IBAT Education Foundation and Merrill Reynolds in Dallas on August 27 for the 2015 Appraisals Summit. This timely course will provide attendees with the general knowledge required to understand and evaluate a commercial real estate appraisal as a key component in the credit risk assessment process for commercial real estate loans. 

Recent examinations indicate that regulators are spending more time looking at the bank’s appraisal process, including the prepared appraisals. According to the Texas Department of Banking, some of the most common appraisal and collateral evaluation deficiencies noted during recent examinations include:

  • Common errors and omissions in the review of appraisals/evaluations (new for the 2015 Summit);
  • Timeliness of annual appraisals/evaluations on Other Real Estate Owned; and
  • Failure to obtain updated appraisals/evaluations in distressed markets when commercial real estate loans are renewed.

Learn more and register here.

2015 Convention

Registration is open for IBAT’s 41st Annual Convention. Now is the time to take advantage of the early bird pricing - expiring on August 7 - and register for the event. For the first time in more than 30 years, the Convention will take place at the Galveston Island Convention Center, September 19-22.  To learn more, you may download a detailed PDF brochure here.

This year’s Convention is packed with educational and networking opportunities, including:

  • Chairman’s tailgate party;
  • State and national bank regulator roundtables;
  • Ten concurrent sessions addressing a variety of challenges you face every day;
  • Songwriters’ late show; and
  • Fishing tournament.

And don’t forget about the Annual Auction and Dream Vacation Sweepstakes, both benefitting the IBAT PAC. You may donate or purchase an item in the Auction or enter the Dream Vacation for a chance to win a $5,000 gift card. Detailed information will be included in next week’s edition of the Bottom Line.

Mobile Alerts Update

Federal Communications Commission (FCC) rules implementing the Telephone Consumer Protection Act require senders to obtain prior express consent from consumers before sending autodialed messages, text messages and prerecorded messages placed on landline phones.

The American Bankers Association (ABA) filed a Petition for Exemption asking the FCC to exempt messages concerning:

  1. “transactions and events that suggest a risk of fraud or identity theft;
  2. possible breaches of the security of customers’ personal information;
  3. steps consumers can take to prevent or remedy harm caused by data security breaches; and
  4. actions needed to arrange for receipt of pending money transfers.”

In its TCPA Omnibus Declaratory Ruling and Order, the FCC granted exemptions for all four categories of messages sent by financial institutions. On December 8, 2014, IBAT submitted a comment letter supporting the ABA petition.

Flag Display

Please be advised by the notice below that President Barack Obama has directed that flags be flown at half-staff until sunset on Saturday, July 25, 2015, in honor of the victims in the recent attack on military recruiting personnel in Chattanooga, Tennessee.   As such, all flags in Texas should be lowered to half-staff for the duration of this period to comply with the President’s directive.

"The President has issued a proclamation in honor of the victims of the tragedy in Chattanooga, Tennessee, which directs the flags be lowered to half-staff beginning immediately until Saturday July 25, 2015 at sunset."

Consumer Tips - July 2015

IBAT’s July Consumer Tips publication that covers the ABCs of buying your first home is available online. Buying a first home is one of the most exciting, and often overwhelming, experiences of one’s life. No matter your age or stage in life, becoming a homeowner is a huge milestone.

We encourage you to share this helpful information with your customers.

Dodd-Frank Turns 5

Today marks the fifth anniversary of the enactment of the Dodd-Frank Act - a date which will live in infamy for community bankers. Five years and tens of thousands of pages of rulemakings later, we continue the fight to protect community banks from the blowback caused by the misdeeds of those deemed “too big to fail.”

As reported in last week’s issue of the Bottom Line, IBAT took to Capitol Hill again to push for a more balanced, reasonable and workable regulatory approach for community banking. While a frustrating process, we do believe there is progress on several fronts as the Senate Banking Committee is working to craft a compromise agreement to its financial reform legislation and the House Financial Services Committee plans to mark up a menu of regulatory burden relief bills at the end of the month. Most encouraging is that in our meeting with FDIC Vice Chairman Tom Hoenig, we were pleased to hear that his “bifurcation” plan was being discussed in Congress.

Further, Congressman Roger Williams introduced H.R. 3048 last week. We were pleased to have played a role in the introduction of this bill. This concept was brought to us by our counterparts in the credit union association, whose members are dealing with many of the same frustrations and expenses of regulatory burden as we are. As detailed in the summary, the CFPB has the authority under Section 1022 of Dodd-Frank to exempt smaller (under $10 B) institutions from particular rules. This bill would require the CFPB to affirmatively include small institutions, based upon justification and evidence of patterns or practices, or they would otherwise be exempt. We appreciate the efforts of Jeff Huffman of the Texas Credit Union Association, and Congressman Roger Williams and his outstanding staff.

If you have the opportunity to invite your respective members of Congress to your bank over the August recess to see firsthand the ridiculous level of compliance expected of community banks, you are encouraged to do so.

Photo (l-r): IBAT Executive Vice President Steve Scurlock and President and CEO Chris Williston witness the signing of H.R. 3048 by Congressman Roger Williams.

Baker Market Update: July 20, 2015

In my 36 years at The Baker Group, I have learned that just because I say it is so, it is not. Therefore, let me try to again revise the course of history with my comments.
We have seen that the events discussed last week happened quickly. Greece ratified an agreement with the ECB, demanding more austerity, and Mario Draghi said he didn’t see Greece leaving the Euro, though comments from Germany seemed to reflect different thinking. In the wake of all this, we watched the Euro weaken, the dollar strengthen, and the Greeks riot in the streets.

Financial Literacy

Final touches are being made for the Texas Financial Literacy Summit taking place July 28-29 in Dallas . The IBAT Education Foundation and the Texas Bankers Foundation invite you to join us at the Dallas Federal Reserve for this Summit. Financial education matters, and the agenda is full of ways to help your bank build a CRA strategy around this important topic. The program will address the following:

  • Why financially literate communities matter for Texas;
  • How financially educated communities support Texas economic development;
  • How Texas teachers are already engaged and making a difference with students; and
  • What the action plan is for local bankers, no matter their efforts to date.

Peruse the brochure, review the full agenda and learn who the presenters, moderators and panelists are here. A special room rate is available at Hotel ZaZa across the street from the Federal Reserve, and the reservation deadline is June 27. We hope to see you there!

Bank Operations

According to the Office of the Comptroller of the Currency’s Semiannual Risk Perspective, one of the biggest challenges for community banks is the operations side. IBAT offers two programs focused on community bank operations to help you respond to every challenge facing your bank:

  1. The Operations Compliance Summit, August 13-14, 2015
    The Summit will explore security and compliance burdens, concerns and solutions. Karen Neeley and Dan Stern of Dykema Cox Smith will provide an overview of recent regulatory changes and litigation of interest, as well as practical recommendations for implementation at your bank.
  2. The Bank Operations Institute, October 11-16, 2015
    This innovative banking program focuses on moving operations officers from the back room to the boardroom, with an emphasis on practical, real-world banking issues and sure-fire solutions. Hosted at the SW Graduate School of Banking at Southern Methodist University in Dallas, BOI takes students through the nuts and bolts of bank operations to a new level of executive strategic thinking.


The July/August 2015 digital edition of IBAT’s magazine, The Texas Independent Banker, is now available online. Click here to view the full table of contents or link directly to specific content below:

As always, if you have suggestions for future content to be featured in The Texas Independent Banker magazine, please contact Bonnie Kankel.

Comfort Crew Check Presentation

Thank you to all who gave a donation to Comfort Care Crew for Military Kids. Yesterday, IBAT presented a check for $5,800 to Comfort Crew on behalf of the community bankers of Texas. This donation will be used by the Comfort Crew to provide kits with age-appropriate support materials to help children cope with challenges they may face growing up in a military family.

Since 9/11, there have been at least 400 military kids a year on average who experience the loss of a parent in a combat-related death. Additionally, more than 2,000 children of veterans are affected annually by the suicide of a parent.

Photo: Christopher Williston presents the IBAT donation check to Mike Mackey, Comfort Crew Board Member.

Community Banker for a Day

We’ve all heard of “Take Your Child to Work Day.” ICBA recently launched a campaign that is an interesting and exciting spin on that concept. As we get closer to the summer recess in Congress, beginning August 3, 2015, ICBA encourages you to invite your congressman and senator to be a community banker for a day.

ICBA’s “Main Street Matters – Community Banker for a Day” campaign leverages the Congressional recess as an opportunity to invite your D.C. lawmaker to visit your bank while home, experience a day in the life of a community banker and understand firsthand why support is critical for community bank regulatory relief legislation.

ICBA offers invitation templates and other materials to prepare your staff for your VIP visitor. Please consider participating in this important campaign.

S. 1711

IBAT supports a recently introduced U.S. Senate bill (S. 1711) that directs the CFPB to allow a hold-harmless compliance period through the end of 2015 for lenders who attempt to comply in good faith with the new TRID requirements, which are effective October 3, 2015.

This bill follows a companion bill filed in the U.S. House of Representatives (H.R. 2213) that provides lenders with a temporary safe harbor from enforcement of the rule integrating mortgage disclosures under the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA).

These bi-partisan measures would protect lenders from private lawsuits and regulatory enforcement actions through December 31, 2015. IBAT will closely follow and report the progress of both pieces of legislation.

New CSBS Chair-Elect

Congratulations to Texas Banking Commissioner Charles Cooper for being elected Chairman-Elect of the Conference of State Bank Supervisors (CSBS) Board of Directors for 2015-2016. He also serves on the CSBS Executive Committee.

Commissioner Cooper held the position of CSBS Board Vice Chair in 2014-2015. Additionally, he currently serves as Chairman of the CSBS Finance, Compensation and Benefits Committee as well as being an active member on the CSBS Audit Committee, Legislative Committee, Regulatory Committee, Emerging Payments Task Force and Community Bank Steering Group.

The Commissioner’s banking career spans more than 40 years and includes senior-level positions in public and private sectors.

Regulation Reform

IBAT staff is back on the ground in Washington, D.C. this week, advocating for the advancement of critical regulatory relief legislation on Capitol Hill.  

“As an industry, we must keep up the heat,” said IBAT President and CEO Chris Williston. “We saw good progress in the first half of the year,” Williston added, “but we need to make sure that community bank issues stay top of mind for lawmakers as we progress through the doldrums of summer.”     

In recent weeks, much attention has turned to the critical need for a delay in implementation of the TILA-RESPA integrated disclosures. With a two-month delay now in place and legislation introduced in both chambers to institute a hold-harmless period for lenders, attention is turning back to the broader regulatory relief agenda.

“As reported to IBAT members during our Tour de Texas earlier this year, it’s essential that we get something done by this fall,” Williston said. “We need to continue to reinforce our message for comprehensive regulatory relief now, and we’re calling upon Texas community bankers to do the same, to ensure we cross the finish line before Presidential politics steal all of the attention in D.C.”

Baker Market Update: July 13, 2015

Accepting the responsibility to carry on for the irreplaceable and irrepressible Lester, I have volunteered to write this week’s LWL. After reading this, Lester may be cutting his vacation short and coming back to resurrect his reputation, but this week’s major news events are going to make this easier to accomplish.
The referendum in Greece was voted down, leaving the European Union with past due debts. Normally that would be a tough situation for a borrower, but Greece feels confident Europe will alter their terms for repayment by the July 12 deadline. And German Chancellor Angela Merkel is doubtful Greece can “deliver a credible plan and is willing to accept a Greek exit”. The Germans are faced with a tough choice: let Greece leave the Euro and deal with the unknown consequences to come or cut a deal and forgive some of their debts which opens the door for Portugal/Spain/Italy to do the same. Wait and see, but this is probably going to get worse before it gets better.