IBAT News

Due Diligence Comment Letter


IBAT issued a comment letter on FinCEN's proposal to develop a customer due diligence ("CDD") regulation. This new proposed CDD regulation is an attempt to bring "uniformity and consistency" in already established mandates such as "know your customer" and "customer identification program." It includes an expanded focus that also addresses two significant issues - customers acting as agents, and obtaining information on a beneficial owner. There is some serious doubt if the information that would be required would prove valuable in a bank's BSA/AML efforts or would assist in any legitimate law enforcement needs. IBAT feels the proposal is very problematic and will have serious unforeseen consequences for overly-burdened community banks.

Vote!


The primary elections are underway . . . early voting started May 14, and runs through May 25.  Election Day is Tuesday, May 29.  You can easily access early voting and Election Day polling locations  by going to your County Clerk’s website.
 
As you have read previously, we have endorsed and contributed to David Dewhurst in his campaign for United States Senate.
 
Additionally, the IBAT PAC has contributed in a number of open seat races in Texas Senate and House contests.  In the Texas Senate, we have made contributions to Ken Paxton (SD 8), Charles Schwertner (SD 5) and Larry Taylor (SD 11).  Open seat House candidates who have received PAC contributions from IBAT include Greg Bonnen (HD 24), Tony Dale (HD 136), James Frank (HD 69), John Raney (HD 14), Justin Rodriguez (HD 125) and Ed Thompson (HD 29).  All of these contributions were made after surveys were sent to IBAT members in these districts.  Several additional contributions are in process, and will be made prior to the May 29 primary elections.
 
Please feel free to call or email Steve Scurlock if you have any questions or comments, and please vote and encourage those in your circle of influence to do the same.
 

Mother's Day


This weekend we honor Mothers everywhere.  Thanks to your attention to family and for all you do.  Happy Mother's Day!

2012 PAC Drawing


Congratulations to Wade Easley, his board of directors and staff at First National Bank of Hereford on being the lucky winners in this year's IBAT PAC Drive drawing. IBAT looks forward to cookin' up some great barbecue for you! FNB Hereford was one of seventy member banks to hold a PAC drive in at least one of their branch locations.

Thanks to all the banks that held a PAC drive.  Your support will keep IBAT working as the only association dedicated to advocating for the interests of community banks exclusively.

Comptroller Susan Combs Meeting


It is going to be an interesting State legislative session to say the least.  That was the conclusion reached by members of IBAT's Executive Committee following an hour-long meeting with State Comptroller Susan Combs in her office late last week.

Combs requested the meeting to better understand challenges faced by community banks and their customers, and to get insights "from the front lines" on economic conditions across the State.  IBAT bankers generally reported that qualified borrowers were still "hunkered down" with so much economic uncertainty.  Combs reported that although State sales tax revenues and oil and gas tax revenues were on the rise, Texas faces significant challenges as state Medicaid funding is expected to increase dramatically as a percentage of state spending (from 20% today to over 37% in 2023) as a result of the Obama health care law.  Combs also expressed concern for local school district debt service which has risen a whopping 152% over the past decade and cited a need for more creative solutions and administrative resource sharing.

Combs is currently conducting town hall meetings across the State in an effort to inform Texans about the very real financial issues that will challenge legislators when they convene in Austin in January of 2013.  IBAT has agreed to help publicize the meetings for the Comptroller in an effort to increase local participation and collaboration.

Congressional Visit Photos


With IBAT's 20th Annual Congressional Visit now in the record books, next year's event has already been scheduled.  Mark your calendars and save the date to join IBAT in Washington, D.C. on April 23-25, 2013.  As IBAT continues to advocate exclusively for community banking, showing up en masse sends a strong message to lawmakers that community bankers are committed to being a part of the process.  

A selection of photos of this year's event are now online. Thank you, once again, to those in the IBAT family who took time to attend this year's Congressional Visit.

Senior Housing Crime Prevention


Earlier this year, the IBAT Education Foundation entered into a partnership with the Senior Housing Crime Prevention Foundation (SHCPF) to help bring Senior Crimestoppers to more senior housing facilities in Texas.  Following conversations with the SHCPF last week, IBAT has learned that more than 100 Texas senior housing facilities in 84 cities have requested the program and are waiting for bank sponsors to help bring it to reality.  

While helping out facilities in their home towns, banks also earn CRA credit through the program and regulators from each of the agencies have issued strong statements in support of the SHCPF.  

"The IBAT Foundation Board approved our sponsorship of this program to offer additional security to those using nursing homes and veteran's homes so they could eliminate the worry of protecting their valuables or their identities. We will all receive a special joy by knowing that we are helping a Senior Citizen feel more secure because this program is in place to offer the security they deserve," said Willard J. Still, Chairman of the IBAT Education Foundation.  

For information about the program, visit the official website or call Peter Gwaltney or Sue Shaffer at 877/232-0859.  For information about Texas bank experiences with the program, call Mary Lange at 800/749-4228.

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Statewide Silver Alert


AFFECTED TEXAS COUNTIES AND/OR NWS REGIONS:
REGIONS - STATEWIDE
         
THIS IS A MISSING SENIOR ALERT ISSUED BY THE TEXAS SILVER ALERT NETWORK

THE PAMPA POLICE DEPARTMENT IS SEARCHING FOR MIGUEL MARTINEZ, DIAGNOSED WITH DEMENTIA, WHITE, MALE, 82 YEARS OLD, DOB 10251929, HEIGHT 5 FT 03 INCHES, WEIGHT 140 LBS, GRAY HAIR, BROWN EYES, LAST SEEN WEARING BLUE AND GREEN BUTTON UP SHIRT WITH TAN PANTS.
                                                                                                         
THE SENIOR CITIZEN WAS LAST SEEN AT 9 PM, ON 05062012 AT 2705 SEMINOLE, PAMPA, TX, DRIVING A LIGHT BLUE, 2001 CHRYSLER TOWN AND COUNTRY VAN WITH TX LICENSE PLATE BK8Z305.

LAW 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 PAMPA POLICE DEPARTMENT AT 806 669 5700.

NEWS MEDIA POINT OF CONTACT IS PAMPA POLICE DEPARTMENT AT 806 669 5700.

Compliance Guy: Get in the Game!


A compliance officer has a leadership responsibility in his or her bank and in the banking industry. This is a particularly important responsibility for compliance officers in community banks. With the recent regulatory changes already made and those being contemplated, it’s imperative for compliance officers to “get in the game” and have their voices heard. One way to do that is with comment letters.

The agencies publish a proposed rule or an interim final rule in the Federal Register for review and public comment prior to its adoption. A proposed rule or an interim final rule describes a new rule or regulation or a change to an existing rule or regulation. Commenting on these is very important as agencies do consider the comments received, and without persuasive comments nothing will change between the proposed rule or interim final rule and the final rule.

Comment letters don’t always work, but effective comment letters can influence the final rule or elicit clarification and additional guidance. They are an avenue you can use to help you become a recognized leader in your bank and an advocate for the community banking industry. Your bank’s senior management and board will be impressed that you took the time to draft an effective comment letter.

So how do you write an effective comment letter? It is much more than saying “This is so unfair and will cost my bank money and will be really hard for me!” In fact, that kind of letter will most likely be ignored as whining. Tone is very important – so the number one rule is to avoid language that is inflammatory or condescending.

Here are some additional tips to consider when writing an effective comment letter.

Click here to read the whole article in the current edition of The Texas Independent Banker.

Senior Housing Crime Prevention


When the IBAT Family looked at the option of adding the Senior Housing Crime Prevention Program to the Foundation's program of work, we were reminded that as people age and they must choose some form of assisted living; they often feel alone. Good people who have spent a lifetime being productive, being good parents and grandparents, paying taxes and being good citizens.We feel that they should not be forgotten.

The IBAT Foundation Board approved our sponsorship of this program to offer additional security to those using nursing homes and veteran's homes so they could eliminate the worry of protecting their valuables or their identities. We will all receive a special joy by knowing that we are helping a Senior Citizen feel more secure because this program is in place to offer the security they deserve.

I am proud of the supporting comments from our bank regulators and I encourage you to read them and help IBAT achieve its goal of adding more community banks by year end to protect more Senior Citizens in our great state. This is true Texas Community banking at its best.

PS: We've learned there are 100 Texas cities with nursing homes which would welcome a partnership with a local community bank. The listing of 100 towns will be posted on the IBAT Foundation website in early May. If you have an interest in being involved with this worthwhile program, take a look. You may call or email our IBAT staff at any time for further information.

by Willard J. Still, Chairman, IBAT Education Foundation

CFPB Overdraft Protection


In February, the Consumer Financial Protection Bureau (CFPB) issued a Notice and Request for Information (Notice) for feedback from consumers and banks on overdraft protection programs (ODP).  Following requests from several stakeholders, the CFPB agreed to extend the April 30th deadline for response to June 29th.  

IBAT urges each of its members to take advantage of this opportunity to make their voice heard in advance of the CFPB issuing rules or guidance affecting ODP. The Notice includes 12 questions regarding ODP, most of which need to be answered with information known only to banks offering ODP. Please forward this Notice to your Head Cashier, Chief Operations Officer, and/or Compliance Officer and ask them to prepare answers to these questions on or before June 29th.  Consumers will likely respond in large numbers; it is important that the CFPB receive reasoned, knowledgeable answers to the questions from community banks.

On April 30, IBAT filed a comment letter in response to the CFPB’s request for information, asserting to the CFPB that the FDIC’s statistics on ODP reflect a product that is working, not failing.  IBAT’s letter informed the CFPB of the background of overdraft payments, consumer alternatives, customer disclosures and information resources, data processing and technology challenges, the economic framework, promotion of responsible use, heavy users, and daily limits.  The letter concluded by stating that overdraft protection is working for the vast majority of customers, and requesting the CFPB to issue guidance recommending (1) customer disclosures for customers with ODP and (2) a fresh start loan approach for those ODP customers who don’t bring their accounts current.

Bank responses to the Notice will focus on the specifics of your overdraft program.  To assist you in drafting a response to this, and other comment requests, IBAT recently published helpful tips in the May/June edition of The Texas Independent Banker magazine.

IBAT Concludes Record DC Visit


Over 130 Texas community bankers and industry partners concluded two days of Hill visits and discussions with all of the federal regulatory agencies last week as part of a nationwide fly-in sponsored by IBAT and ICBA. IBAT bankers visited some 30 members of the Texas Congressional delegation in efforts to promote issues unique to community banks including a host of bills that would provide targeted regulatory relief and to work against efforts by credit unions to expand their member business lending (MBL) authority.

“It was gratifying to see the offices packed with Texas community bankers,” said IBAT President and CEO Chris Williston. “Texas can be proud that our record-breaking crowd accounted for almost 15% of the bankers attending from across the country, and we are in the debt of so many who took the time to participate in the event largely at their own expense.”

In addition to the Texas Congressional visits, participants were treated to a group session to hear addresses by Texas Representatives Pete Sessions, Randy Neugebauer, Jeb Hensarling, Ruben Hinojosa, Francisco “Quico” Canseco, along with Chairman of the House Financial Services Committee Spencer Bachus (R - AL), and senior Senator Kay Bailey Hutchison. Additionally, House Financial Services member David Schweikert (R - AZ) offered his observations on community banking and the legislative process. Group meetings were held the following day with the Consumer Financial Protection Bureau, the Office of the Comptroller of the Currency, FDIC and Federal Reserve.

The annual Washington Policy Summit is one of IBAT’s most important legislative events and has occurred in the spring for the last 20 years, each year exceeding the previous year’s participation.  Our sincere thanks again to all of our IBAT members who participated in this important and impressive showing of commitment to our industry.

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