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ABA National Compliance School
Curriculum & Faculty
(Subject to change)
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Faculty
Patti Blenden Janet Bonnefin Managing Director Treliant Risk Advisors, LLC Phillip R. Freer, Jr. Lucy H. Griffin, CRCM Richard H. Harvey, Jr. Thomas J. Healy Lyn Hall-Fore Gregory Imm Lawrence R. Jackson Lourdes M. Johnson, CRCM Bonita G. Jones Stuart J. Lehr, CRCM Michael D. Maher, CRCM David McCrea Joel Palmer Maureen Prentice Carl Pry, JD, CRP Ryan Rasske Meg Sczyrba, CRCM Dan Soto Chief Compliance Officer Jan Woolsey, CRCM |
Anatomy of a Reg
The course will equip new compliance professionals with skills to better understand and research various laws and regulations. Participants will learn the format and structure of laws, regulations, and interpretive materials. The legislative and regulatory process used by the federal government will be discussed to provide a general framework for understanding where various laws originate and how they are developed and modified into regulations. The course will also offer some general research tips and techniques.
Course Objectives:
1. Students will understand the development of a law from the point of an impetus for its passage through its signing by the President. They will also be exposed to the processes regulators use to develop and implement regulations to fulfill the intent of laws passed by Congress.
2. Students will learn how laws and regulations are structured and modified to enable them to better research laws and regulations.
3. Students will know the structure of the various regulatory agencies and understand which agencies supervise which banks.
4. Students will be provided with some general research suggestions and techniques.
BSA/USA Patriot Act
This course profiles the background, purpose, coverage and enforcement of the Bank Secrecy Act (BSA), as updated by the new components required by the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001, along with other anti-money laundering considerations.
Course Objectives:
1. To understand the background of the Bank Secrecy Act and
2. To understand the reporting requirements and the exemptions to reporting.
3. To review the recordkeeping requirements, including those for funds transfer.
4. To understand the BSA program requirements.
5. To discuss impending (proposed) verification of identity standards under the
6. To understand the requirements for suspicious activity reporting
CRA - Large Banks
This course is designed to highlight the continuing importance of compliance with the CRA and the role of compliance officers in the establishment and monitoring of activities to ensure adherence with the provision of the CRA
Course Objective:
1. Focus on continuing importance of CRA to financial institutions in our current environment.
2. Review performance standards for large bank CRA examinations; identify and briefly discuss the CRA tests for small, limited purpose, wholesale, and strategic plan banks.
3. Discuss importance of internal communication and monitoring procedures for CRA activities.
4. Discuss the impact of internet banking on a bank's CRA performance.
CRA - Small Banks
This course will highlight the Small Bank CRA examination process and options.
Course Objectives:
1. Identify Small Bank alternatives.
2. Review performance standards for small bank CRA examinations.
3. Identify CRA activities and monitoring programs that provide useful bank wide information.
4. Discuss the impact of internet banking on a bank's CRA performance.
Credit Card Compliance
This introductory course provides students with an overview of the requirements of significant regulations specific to Credit Cards (which are not addressed elsewhere in the
Course Objectives:
1. Students will learn about the requirements of Regulation Z, FCRA, Unfair or Deceptive Practices, Telemarketing Sales Rule, USA PATRIOT Act, and Community Reinvestment Act.
2. Students will be able to identify and describe specific credit card disclosures, understand credit card advertising requirements, and know the limitations on the issuance of credit cards.
3. Students will learn about the use of pre-screened applications for credit as defined by the FCRA.
4. Students will gain an understanding of unfair or deceptive practices and how to avoid them.
5. Students will learn about the requirements of the Telemarketing Sales Rule, the National "Do-Not-Call" list, and the application of the "established business relationship" exemption.
6. Students will gain an understanding of the Customer Identification Program (CIP) requirements of the USA PATRIOT Act.
7. Students will be exposed to Community Reinvestment Act for credit card issuers and examination ratings.
8. Students will learn about the requirements of the Fair Debt Collections Practices Act.
E-Compliance
This course discusses some of the fundamental issues of compliance in the age of electronic signatures and the Web.
Course Objectives:
1. Recent (electronic) developments in Compliance
2. Continuing Compliance requirements in the face of electronics
a. Written disclosures
b. Customer signatures
c. Timing
3. Helpful tools for compliance in an age of uncertainty
Elements of a Compliance Program
This course covers the basic elements that virtually every bank's compliance program should include, regardless of size or location of the bank. It will also describe risk-based management approaches. Necessary elements of a successful program include board and senior management oversight; defined, communicated and enforced accountability; necessary policies and procedures; training strategies; internal and external monitoring and auditing requirements; and, examination management techniques.
Course Objectives:
1. Students will understand the key elements that form the foundation of a sound and effective compliance program.
2. Students will learn ideas and examples of various ways that each of these elements can be integrated into compliance programs for banks of varying sizes, resources, geographies and business activities.
3. Students will learn how to document and present their compliance programs to various constituencies such as senior management, the Board of Directors, or regulatory examiners.
FCRA
This course provides students with a better understanding of how the Fair Credit Reporting Act impacts their institutions. The course will focus on uses of consumer reports and limitations on those uses, responsibilities of users of consumer reports in credit and deposit transactions and as employers, and requirements for a party that gives information to consumer reporting agencies.
Course Objectives:
1. To understand what a consumer report is and how its use is limited
2. To understand the bank's responsibilities as a user of consumer reports
3. To learn other ways the Fair Credit Reporting Act impacts a bank's operations
FDIC Insurance
This course will cover the basic principles of FDIC insurance and the specific rules pertaining to all types of customer accounts.
Course Objectives:
1. Students will understand the basic principles of deposit insurance.
2. Students will be able to calculate the deposit insurance of customer accounts.
3. Students will be provided with reference materials to enable them to answer future deposit insurance questions.
4. Students will be knowledgeable of the FDIC's recent simplification of the deposit insurance regulations.
5. Students will become aware of FDIC deposit insurance rules pertaining to Health Savings Accounts, Certificate of Deposit Account Registry Service, and Qualified Tuition Savings Programs under Section 529 of the Internal Revenue Code.
Flood
This course familiarizes the participants with the requirements of federal regulations which apply to real estate lending.
Course Objective:
To provide students with an understanding of National Flood Insurance Regulations.
HMDA
This course is a detailed description of Regulation C which implements the Home Mortgage disclosure Act (HMDA). Through lecture and group discussion, students will become acquainted with the specific requirements of the regulation. The importance of management's involvement will also be discussed.
Course Objective:
1. Determine whether an institution is covered by HMDA.
2. Identify which transactions are subject to HMDA.
3. Properly complete a Loan Application Register (LAR).
4. Identify additional disclosure and reporting requirements of HMDA.
5. Judge the importance of management's involvement.
Management Breakouts
Students will break into small groups based on asset size to discuss a variety of compliance management issues. A faculty member will facilitate each group.
Course Objectives:
As a result of this session, participants will engage in a peer exchange of experiences related to:
1. Specific challenges in managing compliance related to issues such as the following:
a. Oversight and reporting strategies
b. Policy development
c. Procedure implementation
d. Internal control techniques
e. Audit assessments
f. Training and resource management
g. New product implementation
2. Practical solutions and "Best Practices" used by peers to address these challenges.
Managing Your Professional Development & CRCM (Optional)
This course provides new compliance professionals with insights and ideas to better understand available options and paths for their professional development. Participants will hear thoughts and recommendations from veteran compliance and educational development practitioners on ways to further develop their compliance technical knowledge as well as their ability to apply that knowledge to be an effective compliance risk manager. Development of interpersonal skills used by compliance professionals will also be discussed. Participants will learn about and receive a copy of a compliance professional development track assembled by the
Course Objectives:
1. Students will learn about ways they can continue their professional development after completing the
2. Students will gain understanding of the typical career paths for compliance professionals and the various professional development options available to them. Students will also receive information on practitioners' views on some logical sequences in which students might wish to pursue development opportunities.
3. Students will hear from a representative of the Institute of Certified Bankers (ICB) about the Institute and the Certified Regulatory Compliance Manager (CRCM) program and have an opportunity to pose questions about the program and their development in general.
OFAC
This course will provide an overview of Foreign Assets Control laws and the types of compliance programs banks should establish under these laws. The course will cover embargoed countries, specially designated nationals, blocked accounts, licenses and other key terms relevant to Foreign Assets Control compliance. It will also offer suggestions for the development of Foreign Assets Control compliance programs, focusing on the products and services that present the greatest compliance risk factors.
Course Objectives:
1. Provide a basic understanding of Foreign Assets Control compliance requirements and how they impact banks
2. Provide information relevant to the development of Foreign Assets Control compliance programs
3. Identify products and services which present the greatest compliance risks
Privacy
This course addresses the background, purpose, scope and requirements of: Federal Financial Privacy Law and related provisions of other federal and state laws; Interagency Guidelines Establishing Information Security Standards; and the Right to Financial Privacy Act.
Course Objectives:
1. To learn the historical development of the right to privacy.
2. To understand the disclosure and notice requirements of consumer financial information under the Federal Financial Privacy Law, including the limitations on redisclosure of consumer financial information, and the restrictions on sharing account numbers.
3. To become familiar with pertinent provisions of other laws which interplay with Federal Financial Privacy Law, such as the Fair Credit Reporting Act, the FACT Act, the US Patriot Act, and state law.
4. To understand the responsibility to safeguard customer information and properly dispose of customer information.
5. To understand the purpose of the Right to Financial Privacy Act and the requirements of providing customer information to federal governmental agencies under the Right to Financial Privacy Act.
Regulation B
This course delineates the major aspect of ECOA/Reg B from application taking through underwriting and evaluations, to notice requirements and record-keeping requirements. The basic requirements of the Fair Housing Act (FHA) will also be discussed.
Course Objectives:
1. To examine the purpose, scope of coverage and requirement of the Equal Credit Opportunity Act and Regulation B, and the FHA.
2. To determine appropriate and discriminatory application processing practices
3. To examine judgmental and statistical scoring credit evaluation systems
4. To explain spousal co-signature requirements
5. To discuss requirements concerning notifications of actions taken on credit applications, and difference in rules applicable to consumer, small business and other business applicants
6. To review notice, record-keeping and substantive requirements of Regulation B and the FHA.
Regulation CC
This course covers basic provisions of Regulation CC, which implements the Expedited Funds Availability Act. The presentation focuses primarily on the provisions of the regulation that affect customer-contact functions, including maximum check hold periods, exceptions to the statutory hold periods and various disclosures required by the regulation. However, we'll also look briefly at the check processing system as regulated by Reg. CC.
Course Objectives:
1. Explain the purpose of Reg. CC
2. Define key terms used in the regulation
3. Differentiate between using next day availability and availability schedules
4. Explain the timing requirements for exceptions
5. List the necessary disclosures and describe the requirements for each
6. Describe the endorsement standards for checks
7. Explain the responsibilities of various parties for ensuring the expedited return of checks
Regulation DD
This course introduces the student to the provisions of Regulation DD and the Truth in Savings Act, which govern a financial institution's presentation of its deposit accounts to consumers. Through lecture, group discussion and case studies, students will become familiar with the general disclosure requirements, periodic statement disclosure requirements, advertising rules, and annual percentage yield calculations.
Course Objectives:
1. Students will be able to identify which customers and which accounts are subject to the requirements of Regulation DD.
2. Students will know which disclosures must be given to customers at the time an account is opened, subsequent to the account opening, and on periodic statements.
3. Students will be able to identify deposit advertising "trigger" terms and know what disclosures must be made when these terms are used.
4. Students will be exposed to formulas for calculating an annual percentage yield.
Regulations D and Q
This course reviews the fundamental requirements of these two regulations, and the relationship between them. We will review the prohibition against paying interest on demand deposit accounts, as well as the limits on transfer activity from savings and money market deposit accounts. The accounting "nuts and bolts" of Regulation D are not covered.
Course Objectives:
To enable students to comprehend and practically apply the following to their daily responsibilities:
1. Key definitions in the regulations
2. Limitations on transfers from savings accounts
a. What's counted
b. What's not counted
c. Enforcement
d. Penalties
3. Policy implications
4. Issues "On the horizon"
Regulation E
This course reviews the fundamental requirements of the Electronic Funds Transfer Act and Regulation E, with examples. We will also highlight recent and pending changes to the regulation.
Course Objectives:
1. Definitions and scope of the regulation
2. Banks' rights and responsibilities with regard to:
a. Issuance of access devices
b. Disclosures
c. Unauthorized transfers
d. Preauthorized transfers
3. Error resolution procedures
4. Bank and customer liabilities
5. Update
Regulation O
The course covers basic provisions of Regulation O, which governs loans that a bank makes to its insiders (i.e., executive officers, directors, principal shareholders, and their related interests). The presentation will explain who the regulation applies to and the manner in which its provisions apply to various insiders. The course also includes discussion of reporting and recordkeeping requirements a bank must satisfy.
Course Objectives:
1. Students will understand which transactions are covered by the regulation.
2. Students will know the restrictions placed on loans made to insiders and their related interests.
3. Students will understand the reporting requirements Regulation O places upon insiders and financial institutions.
4. Students will be made aware of some of the more common violations of the regulations.
Regulation Z
This introductory course provides students with an overview of the structure and core requirements of Regulation Z, as well as exercises to aid in complying with the regulation.
Course Objectives:
1. Students will learn about the structure and contents of Regulation Z.
2. Students will be able to identify and describe which credit transactions are subject to Regulation Z.
3. Students will learn how to calculate the finance charge and amount financed.
4. Students will understand the difference between annual percentage rates and interest rates.
5. Students will review the timing and format of disclosures applicable to common and specialized loan transactions.
6. Students will review the core disclosure requirements for open-end and closed-end credit.
Regulator Breakouts
This session will provide an overview of compliance and CRA examination objectives, approaches and current priorities. It will provide an opportunity to discuss examination management issues and strategies to promote an effective process.
Course Objectives:
1. As a result of this session, participants will understand:
2. Regulatory examination techniques and philosophies
3. Supervisory priorities
4. Examination ratings and frequency guidelines
5. Deficiencies that trigger problem ratings and enforcement actions
6. Supervisory expectations of an effective compliance program
This understanding will enable you to deal more effectively with compliance examinations at your institutions.
RESPA
This course familiarizes the students with the requirements of the Real Estate Settlement Procedures Act, including the disclosure requirements and the anti-kickback provisions. The course covers requirements and procedures for preparing disclosures, identifying and making special required disclosures of settlement service providers, and identifying and preventing situations that constitute illegal transactions or "kickbacks".
Course Objective:
To provide students with an understanding of the Real Estate Settlement Procedures Act and the compliance requirements that it generates.
UDAAP
This session will summarize recent regulatory advisories and directives to financial institutions regarding unfair or deceptive acts or practices. Risks in this area will be discussed, including requirements of laws and regulations dealing with unfair or deceptive acts or practices. Some recent case examples and accompanying regulatory consequences will be highlighted and potential controls and compliance program components to help address this ever-expanding area will be explored.
Course Objectives:
1. Students will learn about regulatory policy statements and advisories as well as the legal framework related to unfair or deceptive acts or practices.
2. Specific types of and risks related to unfair and deceptive acts and practices will be examined.
3. Examples of practices and activities alleged or found to be unfair or deceptive leading to regulatory enforcement actions will be reviewed.
4. Students will be exposed to potential compliance program implications and compliance tools relating to unfair or deceptive acts or practices.
Questions? Please contact Perette Bonner for more information.
