Silver Alert




POLICE DEPARTMENT is searching for PAT G BROWN, diagnosed
with Alzheimer's, HM, 81 years old, DOB 03/17/1931, HEIGHT 5'4", WEIGHT 140
WITH GRAY PANTS AND BLACK DRESS SHOES.                                                                                                

The senior
citizen was last seen at 10:30 P.M., 10/22/2012 at 1013 JULIUS, VICTORIA, TX,
driving a SILVER, 2004 BUICK LESABRE with TX License Plate


enforcement officials believe this senior citizen's disappearance poses a
credible threat to HIS/HER own health and safety.

If you have
any information regarding this missing senior citizen, contact the VICTORIA

News Media
Point of Contact is

Mortgage Originator Proposal

Under the
proposed loan origination compensation amendment to Regulation Z, if a creditor
pays loan originator compensation, the creditor may not impose any discount
points or origination points or fees unless the creditor makes available to the
consumer a comparable, alternative loan that does not include discount points
and origination points or fees, unless the consumer is unlikely to qualify for
such a loan. To recover costs, lenders may have to set rates at levels that
trigger federal and state high-cost loan laws. Additionally, contributions to
profit-sharing plans and 401K plans may be affected. Finally, the rules would
require bank mortgage loan originators to essentially meet the rules for
licensing non-bank lenders.  IBAT's comment letter brought each of these issues and
more to the attention of the CFPB.

2012 Elections

general election is underway. Early voting started yesterday, October 22, and
runs through Friday, November 2.  Election
Day is Tuesday, November 6
. You can easily access early voting
and Election Day polling locations, as well as sample ballots, by going to your
County Clerk's website, or find information here.

IBAT PAC and IBAT FedPAC have been active this election cycle, thanks to the
generous support of you and your community banking colleagues.  We have
historically followed the "friendly incumbent rule," and have
supported candidates with whom we've worked and established relationships.
 There are few truly competitive races in the general election due to a
redistricting process that tends to result in control for one party.  In
those contests (based upon a list published by "Texas Weekly")
considered even remotely competitive, the IBAT PACs have contributed to the
following candidates:


  • Randy Weber (CD14)
  • Francisco "Quico" Canseco (CD23)


  • Carlos Uresti (SD 19)
  • Juan "Chuy" Hinojosa (SD 20)


  • Craig Eiland (HD 23)
  • Connie Scott (HD 34)

House (continued)

  • J.M. Lozano (HD 43)
  • Jason Isaac (HD 45)
  • Jimmie Don Aycock (HD 54)
  • Dee Margo (HD 78)
  • Stefani Carter (HD 102)
  • Linda Harper-Brown (HD 105)
  • Kenneth Sheets (HD 107)
  • Jason Villalba (HD 114)
  • John Garza (HD 117)
  • Sarah Davis (HD 134)
  • Tony Dale (HD 136)

you have no doubt read in past issues of The
Bottom Line
, the IBAT FedPAC has contributed to both U.S. Senate
Candidate Ted Cruz and Mitt Romney for President.  

We also frequently get questions regarding judicial races from our members. We
have a longstanding relationship with The Texas Civil Justice League (TCJL),
one of the leading tort reform groups in Texas. TCJL endorses judicial
candidates, and we encourage you to take a look at their endorsements in these races.  

Please feel free to call (512-275-2226) or email (sscurlock@ibat.org) Steve Scurlock if you have any questions or
comments, and please vote and encourage those in your circle of influence to do
the same.

Compliance Officer

By Kelly Goulart 

I recently read a post that referred to a bank Compliance
Officer as "...part soothsayer, part counselor, and part sage." No doubt the
role of the Compliance Officer has evolved over time into a position of great
importance and responsibility in any bank, large or small. So what exactly is
the role of the Compliance Officer in the bank today and what makes a
Compliance Officer effective?

A very good resource for understanding the role of the
Compliance Officer - and it can be applied to any banking organization - is the
Basel Committee on Banking Supervision white paper entitled Compliance and
compliance function in banks (April 2005). That high level paper
contains valuable principles that can be used to develop and maintain an
effective compliance program. The following is from the Introduction to that
white paper.

"Compliance starts at the top. It will be most effective
in a corporate culture that emphasizes standards of honesty and integrity and
in which the board of directors and senior management lead by example. It
concerns everyone within the bank and should be viewed as an integral part of
the bank's business activities. A bank should hold itself to high standards
when carrying on business, and at all times strive to observe the spirit as
well as the letter of the law. Failure to consider the impact of its actions on
its shareholders, customers, employees and the markets may result in
significant adverse publicity and reputational damage, even if no law has been

Compliance starts at the top.
Repeat - Compliance starts at the top. An effective Compliance Officer should
be a senior bank officer. As we have said in Legal Ease, the title is
not important but the level of authority is. The Compliance Officer must have
the authority to make and enforce policies. Having established a Compliance
Officer as a senior bank officer, the following are normal duties assigned to
that person:

  • work as a primary liaison between the bank and
    regulatory agencies regarding compliance matters and investigations
  • work with the BSA/AML Officer in the
    preparation and evaluation of regular suspicious-activity reports and the
    coordination of Bank Secrecy Act (BSA), anti-money laundering (AML)
    regulations, and terrorist-financing activities
  • study new banking products and services to
    evaluate risk
  • inform and advise the senior management
    regarding proposed and pending regulatory changes
  • update regulations and communicate the
    same to bank staff
  • administer matters relating to codes of
  • prepare and review materials for
    regulatory training efforts

That is a formal outline of the roles and responsibilities
of the Compliance Officer. A more casual outline would be soothsayer,
counselor, and sage. And a good Compliance Officer will feel comfortable in
each of those roles.

A Compliance Officer is part soothsayer. On a proactive
basis they have to peer into the future and see how potential regulatory
changes will impact current products and business practices. At no time is that
more important than it is now as we face a deluge of regulatory changes
prompted by the CFPB and Dodd-Frank. It is critical that Compliance Officers
utilize a resource like IBAT's Capitol Comments to ensure they are
informed of new regulatory requirements and pending changes to existing
regulatory requirements. Playing catch-up is just not an option.

A Compliance Officer is part counselor. They should
supervise a function that identifies, documents, and assesses the compliance
risks associated with the bank's activities. The Compliance Officer should advise
senior management on compliance laws, rules and standards, including keeping
them informed on developments in that area. During the reporting period, the
Compliance Officer should refer to the compliance risk assessment including any
changes to the compliance risk profile of the bank since the last formal
assessment. A good counselor provides advice and information to senior
management on a regular basis.

A Compliance Officer is part sage. A primary role in the
bank for the Compliance Officer is the education of staff on compliance issues.
They should act as the central point of contact within the bank for compliance
questions from management and staff. Having a "go to person" in the bank makes
it that much easier for bank staff. Good communication skills are very
important for a Compliance Officer.

So there you have it - a good Compliance Officer is indeed
part soothsayer, part counselor, and part sage. Acknowledging the importance of
each of those roles makes the job so much more effective - and rewarding.

Business and Social Media

When it comes to using social media, companies
are more concerned with improving their reputation than they are with
increasing sales, new research has found. More than 20 percent of businesses
say they use social media to build their reputation and their brand, compared
with just 11 percent of businesses that use it to increase sales. More

IBAT Endorses Cruz

Independent Bankers Association of Texas (IBAT) Board of Directors is proud to
announce that IBAT has endorsed candidate Ted Cruz for U.S. Senate. 

recognizes that independent community banks - here in Texas and across the
country - are currently being smothered by one-size-fits-all federal
regulations," Chris Williston, president and CEO of the Independent
Bankers Association of Texas, said. "IBAT supports Ted's efforts to help
create a prosperous economy that will lead to job growth and a positive
economic environment."

Cruz faces off against Democrat Paul Sadler in the November 6 general election.

Solar San Antonio Tour

Borrego Solar
Systems, Inc.
a leading designer, installer and financier of grid-tied solar photovoltaic
(PV) systems, joined TexStar National
October 7 to commemorate the installation of 56-kilowatts (kW) of solar power
installations throughout San Antonio, Texas. The event was held as part of the Solar San Antonio Tour, an annual
open-house tour of solar homes and businesses, coordinated by Solar San
Antonio, a local non-profit organization dedicated to renewable energy

The downtown branch's installation has eliminated 30 percent of its energy
bills, replacing a third of their energy consumption with clean solar
electricity. TexStar is the first commercial lender to go solar in the San
Antonio area, and of the five TexStar branches in the greater San Antonio area,
the downtown branch is the third to have a solar energy system installed.

Speakers for the event included:

  • Manny
    Ruiz, President & Senior Lending Officer TexStar National Bank
    discussed TexStar's decision to convert to clean energy, and how the
    investment is already paying off;
  • Jon
    Sarno, Senior Project Developer at Borrego Solar spoke about the details
    of the TexStar solar installations (how the bank leveraged available
    incentives to make it a cost effective project, the total number of
    installations the bank has invested in and their energy production);
  • Tracey
    Curran-Herman, Board Member of the Phil Hardberger Conservancy shared a
    word about their efforts to provide clean energy and support sustainable,
    reusable, renewable resources for all of San Antonio to enjoy;
  • Ramon
    Flores, Executive Director of the Westside Development Corporation;
  • Gabe
    Farias, CEO of the West San Antonio Chamber of Commerce; and
  • Linda
    Richardson, Director of Communications and Marketing for TexStar National
    Bank invited all speakers and attending TexStar employees to hold the
    ceremonial ribbon.

LegacyTexas Bank

The Shops at Legacy is home to the
newest location of LegacyTexas Bank. The local community bank has announced the
opening of their newest banking center at 7300 Dallas Parkway, Suite A140
Plano, Texas 75024. The full-service facility is on the northeast corner of the
North Dallas Tollway and Legacy Drive and next door to The Capital Grille.

LegacyTexas President Phil Dyer says
the recent opening is a matter of customer convenience. "Easy access from the
Tollway and the continued growth of the Shops at Legacy community make this
location a natural addition to our footprint. Customer service and convenience
are top priority for our bank, and this new banking center reflects that

The Shops at Legacy Banking Center
represents the 21st LegacyTexas Bank location in the Metroplex and the fifth in
Plano. The full service financial center serves both business and personal
banking customers and offers a full range of bank services, including mortgage

"We are excited to be a part of the
Shops at Legacy," said Dyer. "North Texans are drawn to this vibrant area, and
our very personal style of banking fits well within the business and
residential community here."

Hours of operation for the new
banking center are Monday through Friday, 9:00 a.m. to 4:00 p.m. The lobby also
offers an indoor walk-up ATM with 24-hour access. 

LegacyTexas Bank

LegacyTexas Bank is an independent
community bank with $1.6 billion in assets. 
In business since 1963, LegacyTexas Bank currently has 21 branches
throughout Collin, Dallas, Tarrant and Parker Counties. LegacyTexas Group is
the financial holding company for LegacyTexas Bank and also includes
LegacyTexas Insurance Services and LegacyTexas Title. For more information, visit

Contact:  Jennifer Dexter, Assistant VP, 872-461-7157.

Salary Survey

Now is the time
to start thinking about your 2013 compensation and budget planning, so let the Texas Community Bank Salary and Compensation Survey
go to work for you! Take advantage of salary and compensation data from
community bankers across the state to competitively position your bank and
retain bank personnel with confidence. This online product is a
subscription-based, on-demand salary survey customized to meet the needs of
your community bank!

How it

  • Salary
    data may be submitted and updated year-round
  • All
    data is secure and strictly confidential
  • Customized
    Excel and/or PDF reports based on perimeters you set
  • Historical
    data available to track trends
  • In-depth,
    useful salary information to help your bank

is key! The most immediate benefit to participation is preferential pricing but
more importantly: the
more banks that participate, the more valuable the reports become.

Get started today

SNL Financial Agreement

pleased to announce our new relationship with SNL Financial in Charlottesville,

SNL is the
leading provider of financial data and analytical tools for banks. Use SNL to
evaluate your balance sheet relative to peers, optimize your branch footprint
and marketing strategy and assess potential acquisitions. SNL provides a robust
suite of tools to help you evaluate your bank's performance and grow your
business. SNL gives community banks the same advantages enjoyed by the biggest
financial institutions.

As a result
of our new relationship, IBAT members will receive a discount on the SNL Unlimited
database for financial institutions.  If you are interested in learning
more, please contact Julie Jones at jjones@snl.com
or 434-951-4419.

LD Region 9 Meeting

Leadership Division Region 9

you to their regional meeting
benefiting the IBAT PAC!

Wednesday, October 24, 2012
6 p.m.-8 p.m.

Saint Arnold Brewing Company
2000 Lyons Avenue
Houston, TX 77020

Steve Scurlock, Executive

us for a state and national legislative update, brewery tours, silent auction
and food!

thanks to our event sponsors:

Catalyst Financial Company and Doeren Mayhew

Basel III

The tidal
wave of opposition against the Basel III regulatory proposals was bolstered
last week as two prominent voices, the Conference of State Bank Supervisors
(CSBS) and FDIC Director Thomas Hoenig, stepped into the fray.

bank supervisors, we believe there is sufficient justification for higher
levels of capital.  The proposed rules are highly reactionary to the most
recent economic events and do not represent a thoughtful, long-term approach in
the best interest of the U.S. banking system or the national economy,"
said CSBS Chairman Greg Gonzalez in a media release issued by the organization.

criticism of the Basel III proposals was more pointed.  "Basel III is
nearly incomprehensible to most readers, including bank directors, managers,
and analysts. Of what use is a measure that no one can understand?," he
asked in an op ed appearing in American Banker.  He went on to propose
a simpler solution to Basel III concerns in the form of a tangible equity
capital ratio.  

IBAT has
been tireless in its opposition to Basel III, working with members of Congress
and meeting with Federal regulators to make the Texas community bank position

letters from the industry are critical before the October 22nd
feel free to use IBAT's comment letter for guidance, however your personal
commentary regarding how this impacts your bank, your customers and your
community are especially meaningful.  Also, the ICBA website has a terrific array of resources
available to make this process as simple as possible.  Please copy us, as
well as your respective members of Congress and Senators with your
correspondence.  And . . . please don't forget to take a minute or less to
sign the ICBA petition, and encourage those in your circle
of influence to do the same.  

Silver Alert


REGIONS: Fort Worth,
Shreveport, Lake Charles, Houston, Corpus Christi & Austin/San Antonio


The Harris
County Precinct 5 Constable is searching for Jacqueline
Marie Heath, diagnosed with Dementia, White, Female, 80 years old, DOB
10/01/1932, HEIGHT 5' 2", WEIGHT 118 lbs, Gray Hair, Brown Eyes, last seen
wearing a black and white quarter sleeve top, black socks and sandals.                                                                                                   

The senior
citizen was last seen at 1600, 10/10/2012 at 6303 Torrance Elms Court, driving
a Beige, 2005 Toyota Corolla with TX License Plate CT2X431.

enforcement officials believe this senior citizen's disappearance poses a
credible threat to HIS/HER own health and safety.

If you have
any information regarding this missing senior citizen, contact the Harris
County Precinct 5 Constable at 281-463-6666.

News Media
Point of Contact is
County Precinct 5 Constable at 281-463-6666.