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WBA Compliance Center

The WBA Compliance Center is designed to highlight the services your bank can use to stay on top of the various compliance issues you will soon be facing.

The recently passed federal financial regulatory reform bill (Dodd-Frank Wall Street Reform and Consumer Protection Act) will deeply affect the future of the banking industry in Wisconsin. It has been conservatively estimated that the Dodd-Frank bill will generate 5,000 pages of new rules. Banks will be subject to at least 30 new or expanded regulations as a result of the enactment of the most sweeping rewrite of banking laws since the Great Depression. This will add to banks’ already high compliance costs and limit revenue opportunities.

Let WBA help you. Use the resources listed on this page to keep your compliance issues under control.

 

FFIEC Supplemental Guidance

The Federal Financial Institutions Examination Council (FFIEC) recently issued a supplement to the Authentication in an Internet Banking Environment guidance, issued in October 2005. The purpose of the supplement is to reinforce the risk-management framework described in the original guidance and update the FFIEC member agencies' supervisory expectations regarding customer authentication, layered security, and other controls in the increasingly hostile online environment.

The supplement stresses the need for performing risk assessments, implementing effective strategies for mitigating identified risks, and raising customer awareness of potential risks, but does not endorse any specific technology for doing so. The FFIEC member agencies will continue to work closely with financial institutions to promote security in electronic banking and have directed examiners to formally assess financial institutions under the enhanced expectations outlined in the supplement beginning in January 2012.

Read the FFIEC Guidance on Internet Banking Authentication.

  
Dodd-Frank Act FAQs

FDIC has created a series of frequently asked questions (FAQs) related to the Dodd-Frank Act, and more specifically Temporary Unlimited FDIC Coverage for Noninterest-Bearing Transaction Accounts. The FAQs will be updated weekly, and can be found at: www.fdic.gov/deposit/deposits.

  

Latest Compliance News
Treasury releases TIC data
May. 16, 2012
The Treasury has released the March 2012 report of Treasury International Capital data.
314(a) Fact Sheet update
May. 16, 2012
FinCEN has updated the 314(A) Fact Sheet with data current as of May 14, 2012.
NMLS updates data center
May. 16, 2012
NMLS has announced it will be migrating to a new data center May 19-20, 2012. The migration will cause the NMLS to shut down early...
Agencies clarify supervisory expectations for stress testing by community banks
May. 15, 2012
The Federal Reserve, FDIC and OCC have released a joint statement to clarify expectations for stress testing by financial institutions...
Guidance on large bank stress testing
May. 15, 2012
The Federal Reserve, FDIC and OCC have issued a final supervisory guidance regarding stress testing practices at financial institutions...
FinCEN releases SAR Activity Review
May. 15, 2012
FinCEN has released the May 2012 issue of its SAR Activity Review - By the Numbers.
Read more in the archive
  
Interchange Fee Small Issuer Exemption

The FRB has published lists of institutions that will be subject to, and exempt from, the debit card interchange fee standards in Regulation II. The statute exempts any debit card issuer that, together with its affiliates, has assets of less than $10 billion. The lists have been generated from the set of institutions in existence on Dec. 31, 2010, according to available data. The lists, available in Excel .XLS and .CSV format or as .PDF documents, will be updated annually.

  
CRCM Designation

WBA offers a number of programs that qualify for credits toward your Certified Regulatory Compliance Manager (CRCM) designation, and can also be used for continuing education requirements in order to maintain your CRCM designation.

The following WBA programs qualify for CRCM credit:

Loan Compliance School – 42.5 credits
Deposit Compliance School – 23.5 credits
Compliance Officer School – 17.25 credits
Real Estate Compliance School – 20 credits

For more information on these programs, visit www.wisbank.com/Schools.

  
CFPB Model Mortgage Disclosures

In May, the Consumer Financial Protection Bureau (CFPB) asked for comments on its prototype versions of a single, simpler mortgage disclosure form. The financial community responded with more than 13,000 comments. 
 
CFPB since incorporated much of that feedback, along with what it learned in one-on-one interviews with consumers, lenders, and brokers. Now CFPB has asked for banker input once again on the new versions of the forms.

Weigh in now at www.consumerfinance.gov/knowbeforeyouowe.

Visit CFPB's main site: http://www.consumerfinance.gov/.

Any feedback regarding these prototypes can be sent to the WBA Legal Department at wbalegal@wisbank.com.

  
DFI Changes Letter 40

In direct response to bankers’ questions during the roundtable sessions held by DFI over the last several months with the industry, and as a result of the subsequent advocacy efforts by WBA and CBW, DFI reissued Banking Letter 40 related to loans on nonaccrual. The revised Banking Letter 40 is effective as of May 10, 2012, the date of its issuance. DFI made significant helpful changes for state-chartered banks in this revised letter most notably in the provisions related to allowing for the return of loans to accrual status. WBA and CBW appreciate DFI’s prompt action in response to bankers’ concerns. Bankers should carefully review the revised letter to understand its full impact on your specific institutions. Copies of the DFI letter were mailed by DFI to each state-chartered bank and can also be found here.

  
Compliance Toolkits

As part of an ongoing effort to assist members with compliance efforts, WBA is adding a variety of compliance toolkits to its collection.

The latest is the WBA Executive & Incentive Compensation Toollkit. Available free of charge, the 29 page toolkit, created by the Boardman Law Firm, is designed as a starting point to assist the board of directors in establishing sound incentive compensation policies, procedures and practices in compliance with the federal guidelines.

Download any the kits below by clicking here.

WBA Executive & Incentive Compensation Toolkit

WBA FDIC Insurance Changes for Noninterest-bearing Transaction Accounts Toolkit

WBA SAFE Act Toolkit

WBA Dodd-Frank Toolkit

  
WBA Dodd-Frank Resources

WBA has gathered a variety of resources regarding the Dodd-Frank Act. These resources may be accessed by WBA members only by clicking here.

These resources include two Dodd-Frank Act Proposal charts. The first chart (Dodd-Frank Federal Register Table) has been organized by date of publication with the most recent date at the top of the chart. This chart will permit a user to review the most recently added proposals more quickly at the top of the chart. 

The second chart (Dodd-Frank Federal Register Table by Agency) is organized by Agencies to permit user to search for publications by Agency. Again, the most recently published item will appear at the top of the items listed for each Agency publication and will be marked with an Asterisk.

Access the charts and other resources by clicking here.

  
Flood Compliance Solution

What good is flood zone data if you don’t know what to do with it? FEMA says that 119 banks have been assessed $1.3 million in penalties for various violations of the Flood Insurance Reform Act. BancInsure provides more than just flood zone determination data. Its total flood insurance compliance solution addresses your compliance, safety & soundness and customer relations needs, and it won’t cost you anything.

For more information about BancInsure's Total Flood Compliance Solution, click here.

  
WBA Compliance Journal

The WBA Compliance Journal is intended to provide accurate information in regard to the subject matter covered as of the date of publication; however, the information does not constitute legal advice. Click to read a preview of the latest issue of the WBA Compliance Journal.

  
Legal Q&A

The information provided in these articles is not intended to provide legal advice; rather, it is intended to provide general information about banking issues. Consult your institution’s attorney for special legal advice or assistance. Read Legal Q&A articles.

  
WBA Models

Model Pandemic Influenza Plan available
(Updated June 2009 with information on the H1N1 flu virus, and more)
Given the need for financial institutions to create a plan, WBA has prepared a model pandemic influenza plan for WBA members. The model is designed to be used on its own or as part of an institution's broader disaster recovery plan. Since the plan is intended as a model only, it must be customized by each financial institution to their specific situation prior to its implementation and use. Download the model here.

  
Education Opportunities
  
WBA Forms

WBA forms offered by FIPCO have been accepted as standard by bank regulatory agencies, attorneys and the Wisconsin judiciary. In conjunction with legal counsel, these forms are developed and reviewed and constantly updated by the WBA Drafting Team, helping to ensure compliance with State and Federal regulations.

 

Electronic Forms
Electronic files of commonly used WBA forms are available in various formats. These WBA form images are available using Microsoft® Word, Adobe Reader or other third party software systems. The images, or eForms, can be electronically filled out and printed.

WBA Hard Copy Forms
Over 430 forms relating to consumer, real estate, commercial, agricultural and municipal loans; deposit accounts; safe deposit boxes; and deposit and operations are available. Forms are purchased by financial institutions, dealerships, attorneys and realtors.

More information is available here. For more information contact FIPCO Sales.

  
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