Last week, the CFPB released the Small Entity Compliance Guide for the TILA/RESPA Integrated Disclosure Rule. The guide is designed to help you complete the integrated TILA/RESPA disclosures when they become effective on August 1, 2015. The guide may be helpful in the months leading up to the effective date, as your bank considers how to implement the disclosures. The guide also includes all of the model forms.

The CFPB is currently working on a companion guide with details about completing the new integrated disclosure forms. 

Additionally, the CFPB's website has Loan Estimate and Closing Disclosure forms in both English & Spanish and samples for different loan types.   

The Tipping Point

Last week, the Wall Street Journal (WSJ) explored the current trend of mergers and acquisitions among community banks and the high cost of regulatory burden at its core.

"In a period when low interest rates are squeezing small banks, the costs of adhering to new regulations are taking a toll. Executives from at least a half-dozen small banks that have agreed to be acquired in recent months said the increasing regulatory burden was a factor in their decisions," wrote WSJ reporter Michael Rapoport.

In response to the article, IBAT President and CEO Chris Williston penned a letter to the editor calling upon lawmakers to "take some meaningful steps to create a two-tiered regulatory system."

"Community banks are quickly approaching, if not already on the wrong side of 'the tipping point,'" Williston said.  "Unfortunately, the primary force working against [the community banking] model is emanating from the 202 area code."

Over the past year, IBAT has called upon lawmakers to take action towards regulatory reform, rather than continuing to wax poetic on the importance of community banks while failing to take any meaningful steps towards ensuring their survival.

April Discounts from Dell

Due to the popularity of Dell's March promotion, IBAT members can enjoy an extended offer of 40% off all Precision workstations during the month of April. Remember that the benefits of the IBAT endorsement of Dell can be enjoyed by IBAT bank members and their employees!  

Visit Dell's IBAT Member Portal for the latest deals and stackable coupons.  

For more information on these promotions, please visit Dell's website or call 1-800-757-8442 and mention member link ID: GS126658178. For orders of more than 5 units, please reach out to Denney James at denney_james@dell.com or 512-728-8763.

D+H Webcast

IBAT Endorsed Service Provider D+H is hosting a complimentary, virtual coffee break webcast, April 16, that will help you get the keys to adapt and thrive in today's "survival of the fittest" landscape. Discover how to:

  • Streamline GFE point-and-fee accuracy and delivery;
  • Simplify compliance across your organization;
  • Capture essential purchase volume; and
  • Be a hero by helping to make mortgages more profitable.

As a bonus, IBAT members who attend the webcast will receive a free Starbucks coffee! Take a brief tour and see D+H's Mortgagebot online lending and cloud-based origination platform in action!

Click here for additional details.

Week in Review: April 4, 2014

Keep on the sunny side. That’s good advice in general, and generally the best way to look at the latest page-turner from the Bureau of Labor Statistics. Page one tells us that the Unemployment Rate remained at 6.7% in March as Non-farm Payrolls rose by 192k. This morning’s report also contained an upward revision of 37k to the last two months’ job totals. Sunny? Well, maybe partly cloudy since the market was looking for a 200k job increase and a bigger revision rebound after all the talk about the previously reported, weather- affected data. Let’s get back to the sunny side. The Labor Force Participation rose by .2% to 63.2% and the Employment/Population Ratio soared to 58.9% from 58.8%. If one looks hard enough, more sunshine can be found in the .1 increase in Average Weekly Hours and the $4.50 rise in Average Weekly Earnings. Now, before you reach for the sunscreen, the Underemployment Rate... Read more in the Baker Market Update

Flags at Half Staff

Pursuant to Texas Government Code Chapter 3100 and 36 USC 10, and acting in my capacity as the Governor of the State of Texas, I hereby direct the immediate lowering of all flags under state control to half-staff in honor of those involved in the recent shooting at Fort Hood, Killeen, Texas.

Please notify personnel within your agency and other state agency and university leaders of this directive. Flags of the United States and the State of Texas should remain at half-staff from this date through sunset or the end of the flag display day on Friday, April 4, 2014. Flags should be flown at half-staff for the same length of time at all State of Texas offices and facilities in other states and abroad.

Individuals, businesses, municipalities, counties and other political subdivisions are encouraged to fly their flags at half-staff for the same length of time as a sign of respect.

Anita and I send our deepest condolences and prayers to the soldiers, families and support personnel touched by this terrible event.



PAC Drive Update

With March in the books, IBAT thanks all member banks and their employees who participated in our PAC Drive efforts throughout the month. Remember that, even if you weren't able to partake in the month of March, your bank can still participate by holding a PAC drive throughout the year.  

The IBAT Leadership Division has challenged all IBAT member banks to raise at least $1,000 for the IBAT Fed PAC to help strengthen the voice of community bankers in Washington.  

Additionally, IBAT's Associate Member Advisory Council is challenging member companies to hold employee PAC drives during the month of May. At IBAT's Board meetings last week, the employees of First American Payment Systems presented IBAT Executive Vice President Steve Scurlock with a check for $7,012.50 raised by First American employees over the past month.  Our sincere thanks and gratitude to the First American employees.

PHOTO: First American Payment Systems' Rick Rizenbergs, Shawn Dillon, Cody Yanchak and Billy Bourne with IBAT's Chris Williston and Steve Scurlock.

2014 Leadership Conference

Since last year's Leadership Conference with Duck Dynasty's Jase Robertson, IBAT members have been asking, "what are you going to do to top that?"

While we can't promise another Jase, we're eager to roll out our full lineup of speakers for the 2014 Leadership Division Conference, June 26-28 at the JW Marriott San Antonio Hill Country.  Later this week, all IBAT members will receive an email with conference details and a registration link for another great event.

As always, you can count on the IBAT Leadership Conference being an opportunity for you to learn from industry leaders and from your peers as you tackle the challenges facing community banks in a post Dodd-Frank world. And, of course, it will be a family-friendly event with fun for everyone. We look forward to seeing you in June!

HMDA Data Requests

Several banks have contacted us regarding recent requests for HMDA data from Bank of America (B of A). IBAT contacted B of A to determine why these requests were being made, and to solicit additional information.  

In short, it is apparently common practice for the large banks to ask for this information from one another prior to publication of industry-wide data in October of each year, to compare their lending practices with one another in various markets. For the first time, B of A is broadening their scope to include community banks in various markets, presumably those with substantial market share. This is being driven by those responsible for fair lending analysis, and we were assured that the information gathered is kept for internal analysis purposes only.

Our Legal/Compliance team has developed a brief summary to guide you in the event you receive a request for HMDA data from whatever source.  Additionally, please feel free to contact us if you need additional information.  

Happy Anniversary, Chris!

A moment of personal privilege from the IBAT staff today as we pause to celebrate our boss, IBAT President and CEO Chris Williston.  Today, April 1, marks Chris's 25th anniversary with IBAT.

We are all very thankful for the opportunity to work on behalf of Texas community banks, and working for Chris makes it all the better.  

Thanks, Chris, for bringing us all together for a great cause!

Data Breach Update

The House Business and Industry Committee met last week to hear testimony regarding data breaches and what might be done at the state level to address the security of sensitive customer information. IBAT’s Karen Neeley was among those appearing before the committee as part of a financial services panel.  Also appearing were representatives from the retailer’s and restaurant associations, MasterCard and VISA, a security consultant and the CEO of Heartland.

The hearing was informational in nature, and while a number of recommendations were made from the various parties, there was little agreement as to next steps.  IBAT has been actively engaged in this issue over the past five legislative sessions and is in discussions with various parties in preparation for the next legislative session.  We believe it is wrong for banks to pay for fraud losses and card re-issue due to breaches and will continue to work to bring some reason to this process.

We appreciate the response to our recent survey, and the results were helpful in making our case that this is indeed a costly and serious issue. After adjusting for incomplete and duplicative responses, we had good data from 92 Texas chartered banks regarding their losses and costs over a 120 day period covering the recent “headline” security breaches.  Based upon those responses, and extrapolating based upon the assets of all Texas charters, we estimated a cumulative impact of $15.8 million.  

IBAT will continue to press forward with all parties at both the state and federal level on this important issue.  

Baker Market Update: Mar. 31, 2014

Finally, all the widgets have been counted. The initial good news of 3.2% Q4 GDP that was then revised to the less-than-good-news of 2.4% has been re-revised to the little-bit-better-news of 2.6%; slightly below the little-bit-better-than-that expectation of 2.7%. Regardless of which number suits you, the Bureau of Economic Analysis proclaimed, on Thursday, that 2013 is over. As surprising as that revelation may have been to some, it was nothing compared to the proclamation by the NLRB that college football players are actually employees and, therefore, have the right to join a union. The ruling was silent on the rights of cheerleaders... Read more in the Baker Market Update.

CLEAR Act Under Fire

As IBAT and ICBA continue to press forward with regulatory relief efforts in the form of the Community Lending Enhancement and Regulatory Relief (CLEAR) Act, several consumer groups have emerged in opposition to the bill.  The coalition, led by the Center for Responsible Lending,  voiced objection to provisions of the CLEAR Act which would relieve certain community bank loans held in portfolio from new qualified mortgage requirements in particular.

Last week, ICBA responded to concerns raised by the coalition in the form of a letter sent to all United States Senators, maintaining the safety of community bank loans and the need for greater small creditor accommodations.

“In recent years, the delinquency rate of mortgages held by community banks up to $10 billion in assets never exceeded 4 percent, compared to 8 percent to 12 percent for GSE mortgages, 22 percent for fixed rate subprime mortgages and 46 percent for subprime variable rate mortgages. In fact, community bank mortgages have outperformed fixed-rate, prime loans, thought to be the best-performing category of all loans,” the letter read.  “S. 1349 will help community banks serve their customers and communities. It will help deter further industry consolidation that would leave many rural and small town communities without access to customized and competitively-priced banking services.

IBAT staff with strong grassroots banker support have garnered a significant number of Texas Congressional co-sponsors for CLEAR.  The Act currently has 121 co-sponsors in the House and 27 in the Senate.

Flood Insurance Relief

Late last week, President Obama signed H.R. 3370, the Homeowner Flood Insurance Affordability Act of 2013, bringing an end to uncertainty related to catastrophic premium increases for those insured by the National Flood Insurance Program.  As finally passed and signed by the President, H.R. 3370 effectively:

  • reinstates grandfathered status for covered properties;
  • delays the effective date for new escrow rules from July 6, 2014 to January 1, 2016;
  • repeals the home-sale and new-policy rate-increase triggers;
  • provides a refund for people who have realized large premium increases due to the purchase of a pre-FIRM subsidized home without the full transparency from the Federal Emergency Management Agency as to the new rate structure; and
  • requires FEMA to complete an affordability study and to propose an affordability framework to help homeowners cope with dramatically higher premiums.

Silver Alert: NWS Region Fort Worth




The Addison Police Department is searching for James Gary Litzler diagnosed with a Cognitive Impairment, White, Male, 66 years old, DOB 07/19/1947, HEIGHT 6’ 2”, WEIGHT 185 lbs., Grey/ Brown Hair, Green Eye and a Grey Beard and Mustache.  Last Seen Wearing Black Baseball Cap with Vietnam Veterans Insignia and Jeans.

The senior citizen was last seen at 12:00 PM  03/20/2014 at 15701 Quorum in Addison, TX and was traveling on foot.

Law enforcement officials believe this senior citizen’s disappearance poses a credible threat to his own health and safety.

If you have any information regarding this missing senior citizen, contact the Addison Police Department at 972-450-7158.

News Media Point of Contact is Addison Police Department at 214 368-0909.