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Session 1 & 2 – Introduction to Compliance
Dave McCrea, Moss Adams
September 18 & 19
Compliance is a part of banking and touches every product, function, and process within the institution. Compliance isn’t just something the compliance officer or compliance department does; compliance belongs to every person and every function within an institution.
This Program introduces many of the most common elements of compliance and prepares the attendee with a better understanding of a Compliance Management System (CMS) and an understanding of how the CMS is the foundation of many processes, procedures, and functions within an Institution. A CMS is the foundation of the compliance functions, both within and outside of the Compliance Department.
This course requires a basic understanding of the products and functions within a financial institution.
The course will introduce the elements of a Compliance Management System (CMS), including policies, procedures, monitoring, reporting, risk assessments, training, complaint management, and change management.
Session 3: Lending: Consumer (non-RE & Commercial)
Leah M. Hamilton, VP & Sr. Advisor, ProBank Austin
For the past decade, consumer mortgage lending has dominated the role of the compliance officer, leaving many retail and commercial lenders that consumer non-real estate and commercial lending are either not critical compliance matters or that compliance does not apply. This session will highlight non-real estate consumer loan regulations, key considerations and applicable disclosures, including Regulations B (ECOA), Z (TILA), V (FCRA), and more. We will also put an end to the fallacy that there are no compliance requirements in the commercial lending process.
· Understand which regulations and laws apply to consumer non-real estate lending
· Understand which regulations and laws apply to commercial lending
· Understand the impact of exceptions to loan policies
· Identify, detect and mitigate potential compliance risk areas
· Tips for training commercial lenders
Session 4: Lending Real Estate
November 13, 2019
It’s time to take a deep breath and enhance your Consumer Real Estate Lending compliance program. There have been many lessons learned and challenges encountered since we implemented the TILA RESPA Integrated Disclosure (TRID) requirements. We’ll review the core principles, the trouble spots and the regular parade of updates released in 2017 and 2018. The CFPB has also forewarned us that they will be reviewing more improvements and examples that can improve TRID compliance. Be sure to bring your sense of humor and your challenges so we can create effective solutions together!
• Applicable Consumer Real Estate Lending Laws and Regulations
• Flood Insurance Requirements
• Evolution of an "Application" and Related Regulatory Requirements
• TRID Overview and TRID 2.0 and Its Impact
• TRID Construction Loan Conundrum
• TRID Tolerances and Cures
• Regulation Z Rescission Precision
• RESPA Disclosures, Escrows, Section 8 and Other Requirements
• Consumer Real Estate Lending Exam Updates
Session 5: Fair Lending
Sharon Stedman, Principal at Stedman Consulting Group, LLC
December 11, 2019
Fair Lending is an area of compliance where the answer is typically not found in the regulation. This can lead to banks finding themselves the unexpected focus of regulatory attention. Increasingly, compliance professionals must use judgment to weigh the level of risks, rewards, and potential consequences to their bank. This class will provide you with an understanding of how Fair Lending risk is created, identified, and managed throughout the bank and customer experience.
We will start with an overview of Fair Lending laws and discuss how examiners utilize risk factors to assess compliance. Using case studies, the class will identify Fair Lending risk and apply risk mitigation strategies. We will end with a discussion on how to assess Fair Lending risk using existing process and how to develop risk-based monitoring for your bank.
o Understand and apply Fair Lending laws
o Identify, measure and mitigate Fair Lending risk in your institution
o Analyze Fair Lending risk in new products, activities, and policies
o Evaluate the pros and cons of Fair Lending risk monitoring activities
o Identify opportunities to leverage existing processes within your institution to identify Fair Lending risk
Session 6: UDAAP
Meg Sczyrba, US Bank,
January 22, 2020
This session will provide you with both the technical definition and practical application for “unfair”, “deceptive” and “abusive” for financial institutions by examining regulatory guidance and consent orders. After these UDAAP foundations are mastered, students will gain an understanding of how to establish and maintain a proactive UDAAP program throughout the product life cycle. They will also become familiar with the governance protocols to identify and limit UDAAP exposure such as training, risk assessment, monitoring and change management.
At the end of this class, participants will know how to:
· Identify potential UDAAP exposures in internal practices
· Develop a UDAAP program including procedures, marketing reviews, incentive and sales goal reviews
· Create a UDAAP risk assessment and conduct monitoring
Session 7: BSA
Carl Pry, Managing Director at Treliant LLC
February 19, 2020
The Bank Secrecy Act (BSA) is one of the most comprehensive and complex regulations with which banks must comply. Students will learn the extent of the BSA’s monitoring and recordkeeping requirements, such as Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs), among others. We’ll discuss program and risk assessment requirements that banks must meet in order to pass regulatory scrutiny, and then delve into the many requirements of the rules.
As well, institutions must have a culture of Anti-Money Laundering (AML) compliance, which involves most every employee at the bank. We’ll also pay particular attention to the newer aspects of the rules, including the new Beneficial Owner rules, which became effective in May of 2018. We’ll also address the Customer Identification Program (CIP) and Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) rules, and other BSA reporting, including funds transfer recordkeeping, PEPs, pouch rules, and the Office of Foreign Asset Control (OFAC) regulations.
In this session, we'll focus on where the risk areas are and where examiners are criticizing institutions. Your comprehensive program must be continually updated, and we'll make sure you have the information you need to meet expectations.
Covered topics include:
• BSA program requirements, including the 4 (5?) pillars
• Updating your risk profiles, including due diligence responsibilities
• Currency Transaction Reporting hotspots, including exemptions
• Suspicious Activity Reporting - the backbone of an effective BSA program
• Due diligence responsibilities, including Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for high-risk customers
• Selling monetary instruments for cash - collecting and retaining information
• Money Services Businesses (MSBs) – a special type of customer
• Funds transfer recordkeeping - more information collection
• OFAC rules – who and what to screen?
• Blocked & rejected transactions - what's the difference and how do I know which to do?
• Additional USA Patriot Act requirements, such as 314(a), PEPs, and Pouch activities
• Identifying customers and maintaining proper evidence under CIP rules
• Regulatory reorganization of BSA rules
• FinCEN hotspots and areas for review
Session 8: Deposit Compliance
March 18, 2020
With all of the focus on new restrictive lending regulations, it’s easy to overlook the importance of the deposit regulations. However, the deposit area continues to grow in complexity and risk. Our deposit compliance session will focus on critical definitions and operational risks as we discuss this challenging area of regulatory compliance. As payments continue to evolve and speed up, we must enhance our deposit risk management systems. Our personnel have to be well versed in all of the regulations and statutes, as well as operational requirements from our payment partners.
We’ll dig deep into the legacy regulations and the newest additions to our deposit arena, from ATM and debit card transactions, to ACH, prepaid accounts and gift cards, overdraft opt-in program, foreign remittance transfers and good old paper checks and remote deposit capture that continue to challenge our Regulation E resources. We’ll look at the continuing risk of deposited paper items and how it impacts our consumer and commercial customers in Regulation CC. It’s important to remember the restrictions related to savings accounts in Regulation D and the changes in monitoring as a result of new payment methods. In this environment of UDAAP compliance as a regulatory umbrella expectation, we must also consider the foundational principles of Regulation DD, ensuring our consumer customers are well versed in how the deposit accounts function.
· Electronic Fund Transfer Act and Regulation E
· Expedited Funds Availability Act and Regulation CC
· Restricted Transactions on Savings Accounts and Regulation D
· Truth in Savings Act and Regulation DD
Session 9: Regulatory Soup
Leah M. Hamilton, VP & Sr. Advisor, ProBank Austin
Often times the compliance officer focuses on deposit or lending specific regulations. The Regulatory Soup session will highlight the enterprise-wide regulations, such as Privacy, eSIGN, advertising, social media, insider lending requirements and deposit expectations, fair banking, the compliance officer’s role in cybersecurity planning and response, and more.
· Understand essentials of enterprise-wide laws, regulations and guidance
· Understand key considerations for managing compliance risk of enterprise-wide regulations
· Incorporate enterprise-wide regulations in monitoring schedule
Session 10 – Wrap Up/What to tell your CEO
Dave McCrea, Moss Adams
May 20, 2020
This session summarizes the material covered in the first 9 sessions and highlights a financial institution’s inherent compliance risks and the controls necessary to mitigate the risks. In addition, the session will provide an overview of the examination agencies, the examination process, and the examination rating systems. The session will also highlight current industry high-risk areas identified from consent orders, civil money penalty assessments, and legal complaints. The focus will be on implementing effective controls to mitigate the risks identified.
* Attendance at WBA programs is limited to employees, officers and directors of WBA members, non-members eligible for membership in the WBA and members of other state banking associations which grant reciprocal privileges to WBA members.
Cancellation Policy: For all cancellations that occur up to seven days prior to the start date, a $50 cancellation fee will be charged. For cancellations with less than seven days notice, there will be no refunds. A substitute can attend at no fee. For cancelled courses and/or seminars, full fees will be refunded.
Cancellation Procedure: Cancellations must be sent in writing to the WBA office via email, fax, or mail. No refunds will be granted until a written cancellation request is received by WBA.