Basel III Carve-Out?

Last week, 53
Senators, including Texas Senators John Cornyn and Kay Bailey Hutchison, signed
a letter urging federal regulators to consider the
unintended consequences of including community banks in the Basel III Capital
proposals. As always, IBAT extends our sincere thanks to our Texas Senators for
their continued support of community banking.  

proposed capital rules are extremely complex and require the reporting and
maintaining of granular data, greatly increasing the compliance burden on
community banks," the letter noted.  It went on to cite the
challenges that community banks would experience raising capital as a result of
Basel III, and offered the concern that community banks might have to change
their business plans in ways that would reduce lending and economic growth.

The comment
period for the Basel III Capital proposals ends on October 22. Please see IBAT's letter for assistance in writing your
personalized comment letters.

Leadership in Action

Though we're in the digital age, personal
recommendations still go a long way in business. Word-of-mouth referrals
account for a good portion of new customers for many small-business owners, and
the ease of making recommendations is only made simpler with email and social
networking. Incentivizing your current customers to refer their friends and
contacts can boost business. Here are a few ways you can get the most from
referral incentives. More

Basel III Calculator from FDIC

federal regulators released a tool for estimating the potential
impact on banks as a result of the Basel III capital rules.

The new
calculator-which is an Excel spreadsheet-has been pre-populated with bank data
from the June 30th call reports. As mentioned in previous weeks,
IBAT encourages all members to write customized comment letters on the
proposals before the October 22nd deadline.

For your
convenience, a link to the IBAT comment letter to federal regulators can be found here.

Electronic Federal Benefit Payments

Source: U.S. Department of the Treasury, Financial Management

who receives Social Security/Supplemental Security Income or other federal
benefit payments by paper check is required by the U.S. Department of the
Treasury to switch to an electronic payment option by March 1, 2013.

new public service announcement, five educational videos and print materials
are now available to help you assist the people you serve with common questions
about the requirement and getting payments electronically. Videos feature
actual customer service agents from the U.S. Treasury Electronic Payment
Solution Center and answer the following questions:

  • Why
    is the U.S. Treasury requiring electronic federal benefit payments
  • How
    will I know my money has been deposited?
  • How
    does direct deposit work?
  • Are
    electronic payments safe?
  • How
    does the Direct Express® card work?

can view the PSA and educational videos on GoDirect.org or by visiting its YouTube channel. Print materials can be downloaded
from the Educational Videos and Fliers toolkit on www.GoDirect.org.

To order a looped DVD of the videos, contact a Go Direct campaign
representative by emailing GoDirect@webershandwick.com or by calling 952-346-6055.


Have you downloaded IBAT2GO, the official
mobile application of the Independent Bankers Association of Texas?  If
so, show us your IBAT pride by having a friend snap a picture of you using the
app, and you'll be entered into a drawing for a new iPad!

Don't have
an iPad/iPhone, so you can't download IBAT2GO?  Take a photo of yourself
using someone else's iPhone or iPad, or send an email to Christopher Williston
without a photo, by October 1, 2012, indicating your desire to enter the

Click here to view official contest rules.

IBAT Convention

The 38th Annual Convention is a little more
than a week away! The event will take place at the Hilton Austin Hotel, October 6-9. The IBAT
staff is diligently working on putting the final touches on making this event
more valuable than ever. There's still time to register

you're not sure about what to expect, here's a sneak peek:

  • Nationally
    renowned speakers and general sessions;
  • Banker
    peer resource sharing;
  • Annual
    PAC Auction;
  • Bike
  • Classy
    and fun entertainment;
  • Golf;
  • Much

you have questions or need any information about registering, please don't
hesitate to contact our registrar Jennifer Roe (512.275.2213 direct line) or
email her at jroe@ibat.org.

Support the IBAT PAC

Three days and two nights at one of the Caesars Entertainment properties in Las Vegas, Nevada. Offer is good seven days of the week but excludes holidays and special events. The offer expires on June 1, 2013. Donated by Michael Moores, Citizens National Bank, Henderson.


Take a look at all of the items that have been donated so far.

IBAT Comment Letter

IBAT submitted a comment
letter opposing the Financial Accounting Standards Board proposals under
Disclosures about Liquidity Risk and Interest Rate Risk (Topic 825).
IBAT believes the requirements do not provide information that would be
useful to community
bank investors.  Additionally, the proposed disclosures as constructed
may provide false assumptions of future risk and provide no meaningful
basis for comparison.  Finally, the cost to audit and produce the
information in a bank's annual financial statement
would be significant, and expands the ever-increasing financial and
regulatory burden already faced by community banks. To read IBAT's
comment letter

click here

Leadership in Action

People describe the modern workday as a firefight. Emails are constantly coming at you, seemingly requiring an instant response. There's no time to think except outside of normal business hours. And that doesn't seem very fair if you want a normal life, too. But some of this urgency may be more perception than reality. We inflict it on ourselves. Here's how to establish new habits. MORE

Basel III Comment Letters

Last week, IBAT filed its comment letter with the OCC, Federal Reserve, and FDIC relative to the Basel III proposal.

IBAT is committed to obtaining an outright exclusion for community banks, regardless of size, or at the very least, obtaining significant modification to the most damaging provisions.

Many of you have been waiting for IBAT's letter in order to model your own letters well in advance of the October 22, 2012 deadline for comments.  We strongly urge that you take time right now and submit a letter on behalf of your bank and shareholders.  The industry must be heard on this defining issue that may well determine the ultimate survival or demise of community banks.

IBAT previously sent your bank a spreadsheet, prepared by Fisher, Herbst, and Kemble, a CPA firm out of San Antonio, to help determine the impact this proposal will have on your bank's Tier I capital.  It is our understanding that the agencies are also developing a calculation instrument but it will not be available for some time.  If you have questions about the spreadsheet, please email Alan Rich.

When used along with IBAT's comment letter and previous information provided by IBAT, we believe you will find the spreadsheet to be a useful tool in drafting your comment letter.

We stand ready to assist you in your efforts.  Let us know how we can be of service.

Tax Lien Lender Questions

Burt R. Solomons asked the Texas Attorney General questions about the
respective roles of the tax assessor-collector (the "Collector") and
the governing body of a taxing unit in relation to the transfer of a tax lien
to a third party who pays a property owner's property taxes. The Attorney
General answered the questions as follows: (1) The Collector, acting alone,
must carry out the ministerial duties related to the transfer. Neither the
Collector nor the governing body of the taxing unit is empowered to deny the
transfer of a tax lien if the conditions of section 32.06 of the Tax Code are
otherwise met.  (2) A court could conclude that closing costs and lien
recordation fees charged by a property tax lien transferee under section 32.06
of the Tax Code are secured by the transferred tax lien.

With regard
to the second answer, the Opinion recognized that the statute does not
specifically address charges or fees with respect to the recording of the lien.
 It concludes from this absence that it could be argued that lien
recording fees are not among the charges, fees or expenses expressly authorized.
 However, the Attorney General also found support in the Tax Code that any
charges and fees included in the contract between the property owner and the
transferee are secured by the transferred lien. Therefore, the Opinion
concluded that a court could conclude that closing costs and lien recording
fees are secured by the transferred lien.

FDIC Compliance Teleconference

FDIC has scheduled its next compliance teleconference for this Thursday,
September 27, from 1:00 to 2:30p.m. central daylight time. FDIC
staff from the Division of Depositor and Consumer Protection will focus the
call primarily on the Consumer Financial Protection Bureau's (CFPB)
mortgage-related proposals, including:

  • Mortgage
    originator standards,
  • Appraisals
    for "higher-risk" mortgages,
  • Equal
    Credit Opportunity Act appraisal requirements, and
  • Mortgage

Advance registration for the teleconference
is required but free of charge.    Please click
to register for the teleconference.