Fourth Quarter 2016
Q&A with CBA Incoming Chairman
Michael Rauh
Fourth Quarter 2016 • Connecticut Banking Magazine
Fourth Quarter 2016
Q&A with CBA Incoming Chairman
Michael Rauh
COVER STORY
Q&A with CBA Incoming Chairman Michael Rauh.................. 8 CONNECTICUT BANKERS ASSOCIATION
10 Waterside Dr. Farmington, CT 06032-3083 Telephone: 860-677-5060 • Fax: 860-677-5066 Chairman Richard J. Cantele President & CEO Salisbury Bank & Trust
Second Vice Chairman Michael J. Casparino President Northern Connecticut, People’s United Bank
First Vice Chairman B. Michael Rauh President & CEO Chelsea Groton Bank
President & CEO Lindsey R. Pinkham
Executive Vice President & Treasurer Thomas S. Mongellow First Senior Vice President & Secretary Colleen E. Clancy
FEATURES
Succession Planning: How Deep Is Your Bench?.................................................... 4 HSAs and Generation X: From Overlooked to Opportunity........................................... 6 Upcoming CBA Calendar.................................................... 11 The New URLA Is Here … with Time to Spare............................................................. 12 CFPB Researches and Issues Recommendations on Elder Financial Exploitation............................................. 14
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The Compliance Alliance Model..................................... 16 Dodd-Frank’s Price Tag................................................. 17 Bankers in the News..................................................... 18 Banks in the News........................................................ 20
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Connecticut Banking Magazine • Fourth Quarter 2016
Succession Planning: How Deep Is Your Bench? By Jim Edrington
S
uccession planning is a concept that is gaining more and more prominence, and for good reason. As Baby Boomers continue to retire in record numbers, banks are faced with making decisions about key positions that will impact their future success and it’s important to “get it right.” Boards of directors play an important role in this process – helping to ensure the bank has a robust and effective process for identifying top talent and ensuring a smooth transition for key management positions, especially in the C-Suite. Succession planning is all about ensuring you develop your “bench” – recruiting and developing the talent that represents the future – and instilling in these employees the knowledge, skills Jim Edrington and abilities (referred to as KSAs) to enable them to be successful in their current roles and well-positioned to take on increasing areas of responsibility and more challenging jobs. A formalized succession planning process to support this objective provides several key benefits, including: • Identifying the key roles in the bank’s management structure. • Documenting the critical skills and competencies needed to support strategic objectives. • Identifying potential internal candidates for succession by job role. • Assessing whether internal candidates possess necessary job skills. • Communicating the importance of succession planning to all key stakeholders.
self from the financial downturn, banking will be positioned once again as a “career of choice.” A dynamic culture is also being created in many community banks that provide opportunities for people to grow and advance. This culture development requires the full support of the CEO, the board and senior leaders. When properly executed, culture can be a competitive advantage and a key opportunity to reach out to the new generation of bank employees (the much-talked-about Millennials). The board has many competing responsibilities – especially given the current regulatory environment and importance of risk management oversight. Your shareholders and regulators want to know that you have in place a solid plan of action as part of the bank’s long-term vision or if called upon in an emergency. This fiduciary responsibility goes beyond the CEO’s office and includes most other key positions, including division heads. Not only must the board address the risks associated at the CSuite level, it must also look internally at director succession to ensure that the board’s composition continues to satisfy the needs of the bank. It’s important to integrate this level of review into the annual process leading to the recommendation of the slate of directors in support of the annual shareholder vote. Additionally, boards must consider the key skills required to serve as a director, who in the community may represent ideal candidates and how best to attract these individuals. Given the demands on these individuals in their current day jobs, and the increased level of governance required of bank boards, this can often be a challenging proposition. Proper planning and the development and management of a well-thought-out succession planning methodology will go a long way toward ensuring that your board of directors remains vital and serves the bank well. Having a culture that recognizes the importance of leadership development, as well as the discipline to identify critical roles and functions – with an eye towards the future – can help position a bank for continued growth and success. u
From the ABA’s perspective, the industry has embraced the need for succession planning and is taking concrete steps to address talent gaps. Many state bankers associations have taken steps as well, such as implementing emerging leaders programs to engage younger bankers in the advocacy process and help them develop their skills and professional networks. The graduate banking school marketplace is seeing a resurgence and, in some cases, record attendance levels, further demonstrating the investment many banks are making in their future. A clear byproduct of this heightened interest in succession planning and leadership development is that as the industry distances it-
Jim Edrington is executive vice president of professional development at the American Bankers Association. Email Jim Edrington at jedringt@aba.com.
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Connecticut Banking Magazine • Fourth Quarter 2016
HSAs and Generation X: From Overlooked to Opportunity By Kimberly Sexton
care costs. They see their parents, who have largely retired, as not doing as well financially as they hope to be when their time to retire comes along. They also are the first generation to experience the switch from pensions to defined contribution plans. Add to that, Generation X experienced two market downturns early in their saving years (2000–2002 and 2007–2009), which affected future growth significantly. Generation X is perhaps the most flexible generation when it comes to receiving information. They love in person and they love technology. But most of all, they love simplicity. They already have a lot on their plate and don’t have time to sort through complexities. Because of this, they tend to like consolidation, which is great for financial organizations. Having their checking, savings, HSA and loans all at one place is appealing to them. However, because Generation Xers are providing financial support to both baby boomers and millennials, their savings rate into HSAs is not as high as it should be to adequately prepare for their future. Add to that, 66 percent of Generation X accounts have distributions, which can be good for financial organizations because of the interchange fees, but bad for saving for the future. Knowing these key characteristics is helpful as you develop a plan to market to this particular group. But what does Generation X want in an HSA? Just three things: • Interest: With the average interest rate of about 0.05 percent in many HSA accounts, anything better than that is worth the switch. • Ease of access: This generation carries more plastic than any other so a debit card is critical. • Online banking: This generation doesn’t have time to come into a branch.
I
If you search online for generations in the U.S., you will find copious articles about Baby Boomers and Millennials. But don’t forget the generation in between those two: Generation X. Today, those are the people generally between the ages of 37 and 51. They represent approximately 64 million people. In contrast, Millennials and Baby Boomers each make up about 75 million people. Generation X may be the most overlooked generation, partially because of its size and the number of years it spans. But when it comes to the business of health savings accounts (HSAs), you won’t want to overlook this group. With roughly 40 percent of HSAs owned by Generation X, based on data from the Employee Benefit Research Institute (EBRI)1 , the HSA market is one area that Generation X seems to dominate. Marketing to Generation X is well worth the effort if you keep in mind some key characteristics about Generation X. It is a generation stretched thin, sandwiched between caring for children and parents. Meanwhile, Generation Xers are wondering if they are doing enough to prepare for their own retirement and health-
Generation Xers heavily influence the HSA market because of the support they lend to the two surrounding generations. They have higher average incomes than both Boomers and Millennials. They like messaging that speaks to them directly. They look for authenticity and real-world situations they can identify with. And once you have them as a customer, they are brand-loyal. u Kimberly Sexton is a vice president at Ascensus with more than 20 years of experience in the benefits industry. She has been with Ascensus for more than 10 years and was previously a vice president with Merrill Lynch and Amvescap Retirement.
Footnotes 1. Paul Fronstin, Ph.D., “Health Savings Account Balances, Contributions, Distributions and Other Vital Statistics, 2014: Estimates from the EBRI HSA Database,” Employee Benefit Research Institute, July 2015, accessed July 1, 2016, www.ebri.org/pdf/briefspdf/ EBRI_IB_416.July15.HSAs.pdf.
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Connecticut Banking Magazine • Fourth Quarter 2016
Michael Rauh Q&A with with CBA Incoming Chairman
Connecticut Bankers Association Chairman Michael Rauh came to community banking via an unusual path in the financial industry – he was hired by a bank after a career in marketing for financial services companies. He now leads Groton-based Chelsea Groton Bank as its president and CEO.
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Fourth Quarter 2016 • Connecticut Banking Magazine
Tell our readers about your banking career. It started somewhat accidentally but in hindsight, it happened through a very fortuitous series of events. I enrolled at the University of Rhode Island in 1977 thinking I wanted to be a naval architect. I quickly realized that wasn’t for me, and ended up getting a degree in economics, with no intention of applying it in the “real world.” While at URI, I spent most of my free time at WRIU, the campus radio station, selling advertising among other things. My first postcollege job was selling ads for a local arts publication. That led to a series of sales and marketing jobs that culminated in working for an advertising agency, which specialized in marketing for financial services companies. I serviced banks, insurance companies and mutual funds. When the head of marketing position with one of my clients – a bank – became available, I was offered, and accepted, the job. It was 1991. The bank had six branches and about $300 million in
assets. Over the next 19 years, the bank and I would grow together. I was fortunate to have fantastic bosses and great co-workers, and to lead my department through a lot of growth and change. We tripled the number of branches, added a call center and got into online banking. I also had the opportunity to lead a number of corporate initiatives, including strategic planning and bank-wide sales. In 2010, I was fortunate to be hired as president and CEO of Chelsea Groton Bank, replacing Duncan Stoddard, a legend in Connecticut banking and our region. The five-plus years I’ve spent here have been the most rewarding of my career. It’s a very special place – both the bank and the region. As a mutual bank, the connection to our customers and our communities is extraordinary. And the diversity of the area – demographically, geographically, economically – is really exciting. It’s an incredibly vibrant community with a rich history.
Like many bank executives you serve on many boards – how do you find the time? Community involvement is one of my favorite aspects of working for a local bank. It’s a great way to meet people and feel the pulse of the world around you. Right now I serve on seven boards: L&M Healthcare System, Chamber of Commerce of Eastern Connecticut, the Eugene O’Neill Theater Center, the Norwich Free Academy Foundation, the Norwich Community Development Corporation, URI Harrington School of Communication and Media and the Providence Mutual Insurance Company. Those are in addition to our bank board and bank foundation board. I’ve tried to be strategic about being involved in a wide variety of causes spread throughout our market area. I feel lucky to be involved
in these organizations, and I learn so much from their talented management teams and my fellow board members. There are many common issues, regardless of size or organization type, and being involved in so many organizations allows for cross pollination of ideas. Juggling a full time job, community involvement and family is definitely a challenge. Basic time management skills and constantly re-setting priorities allow me to keep up. I have to give a huge amount of credit to my assistant, Sue Olszewski, who works magic behind the scenes, and to my team at Chelsea Groton. They really do all of the heavy lifting at the bank.
Tell us about Chelsea Groton Bank, its history and the communities it serves. The Groton Savings Bank was founded in Mystic in 1854 and The Chelsea Savings Bank, named for a section of downtown Norwich, was founded in Norwich in 1857. The two banks merged in 1982 and became the bank we know today. We have copies of the first bank charters, which list the original corporators, who were all community leaders at the time. It’s humbling to drive around the region and see their names on streets, buildings and businesses, and realize what an impact these folks had on the area. Each bank began as a “mutual” organization, formed for the good of their customers and the communities they served. I’m very proud that 162 years later, we are still true to that original mission.
We’re currently more than $1 billion in assets, have 15 locations and offer customers all the modern conveniences. I know our founders would be proud that we still focus 100 percent of our attention on making our customers successful, and helping to make the communities we serve better through our contributions of time and money. Besides a commitment to service, and investing in the technology that helps make banking more efficient, we place a huge emphasis on customer and community education. For our 150th anniversary, we created a full-time community education officer position. We offer ongoing, varied financial literacy curriculum for all age ranges in our branches and at community centers, senior centers, schools and libraries. continued on page 10 9
Connecticut Banking Magazine • Fourth Quarter 2016
Q&A with Michael Rauh continued from page 9
What is the bank doing to attract the next generation of customers, the Millennials? Millennials are certainly a hot topic and like many other companies, they’re a group that we’re interested in targeting. The average age of a Chelsea Groton customer today is 54, so getting younger for us is about more than just Millennials. We think a lot about attracting Gen X, Gen Y and younger Boomers, as well as small businesses. From a product standpoint there are clearly some differences among the generations. In very broad terms, younger folks are interested in free checking with a debit card that has free access to ATMs. They’re also looking for “starter” products like credit cards and car loans. As they move through life, mortgages and money
market accounts start to pique their interest and eventually, investment products. In addition to offering a competitive set of products that spans the changing needs of our customers, we make personal connections with people, to help them find success at every life stage. We do a lot of “handshake” marketing in the community, sponsor programs, host seminars, attend events and more. Advertising and marketing does a great job of creating awareness and building the brand, but the real business is won through the referrals we get from providing extraordinary service, and going above and beyond to help people.
The bank puts a heavy emphasis on personnel training, as evidenced by the number of successful CSFM graduates over the years; how does the bank select its candidates and do you find their attendance to the program beneficial? The key to providing exceptional service is to start with great people, and then give them the tools they need to be successful. Knowledge is one of the most important tools we can provide. We are big believers in programs like the Connecticut School of Finance and Management, Stonier National School, CFT, the local Chamber Leadership program, professional certifications and our own programs – Chelsea Groton University and the Chelsea Professional Management Series.
Senior managers nominate employees for the Connecticut School of Finance and Management, Stonier National School and the Leadership program. Together, we work to identify talented team members with potential for growth, and decide who we’re going to send. We think about it the way a professional baseball organization thinks about their farm system. We have our own Chelsea Groton University that combines a host of in-person and online learning opportunities. We use an online por10
Fourth Quarter 2016 • Connecticut Banking Magazine
tal to manage the program which includes all required annual employee training modules. It also offers specific curriculum based on job function, soft skills training, technical training, and certificate programs. In addition, we launched the Chelsea Professional Management Series (CPMS) two years ago, and graduated our first class last fall. As part of the CPMS, managers attend 20 courses over an 18-month period, on topics such as leadership strategies, communication, management during change and more. We have a generous education reimbursement program. I’m always proud to attend the annual CFT dinners and see how many team members have earned certificates. There are also a number of employees working on their bachelor’s degrees part time while working for us, and we’re happy to make that financially possible for them. At the end of the day, this is a service business. That means we are completely dependent on the members of our team to take care of our customers. Being able to provide the right guidance and advice requires knowledge. Education and experience are the only ways to get there. There really aren’t any shortcuts, so we make the investment for the long-term good of our customers and our company. u
Upcoming
Free money. First-come, first served. Really. For a limited time, we’re offering members zero-percent Classic Advances to create or preserve jobs in their communities. Our new program, Jobs for New England, will award up to $5 million in interest-rate subsidies every year through 2018. A maximum of $250,000 in subsidy is available per member each year. At current rates, $250,000 can leverage up to $30 million in one-year advances. To find out more about Jobs for New England, contact Fatima Razzaq at 617-425-9564, or fatima.razzaq@fhlbboston.com. But don’t delay. These funds won’t last forever.
See what your cooperative can do for you!
FHLBBoston Federal Home Loan Bank of Boston • 800 Boylston Street Boston, MA 02199 • www.fhlbboston.com
CBA Calendar
OCTOBER 2016 12
FMS SEMINAR
FEBRUARY
19
CSFM 2018
7 8
CSFM 2017, 2018 FMS SEMINAR
NOVEMBER
MARCH
4 9 16
7 7 TBD
FDIC OUTREACH SEMINAR CECL SEMINAR CSFM 2017, 2018
DECEMBER 1 6 7 8
FMS SEMINAR CSFM 2017 CSFM 2018 DIGITAL ASSETS SEMINAR
JANUARY 2017 4 4 12 13
CT LEGISLATIVE SESSION COMMENCES CSFM 2017, 2018 NEW LEADERS AWARDS CEREMONY BANKWORLD 2017
CSFM 2017, 2018 CALL REPORT MORTGAGE SYMPOSIUM
APRIL 4 9-12 18 27-28
CSFM 2018 CSFM 2017 BANKSIM/GRADUATION CSFM 2018 WOMEN IN BANKING
MAY 2 2 16 23 11
CSFM 2018 FMS SEMINAR DIRECTOR & SENIOR OFFICER SYMPOSIUM CSFM 2018
Connecticut Banking Magazine • Fourth Quarter 2016
The New URLA Is Here … with Time to Spare By James McGuire
J
ust when banks thought they couldn’t get enough of Regulation Z and RESPA, the recent flood insurance changes and the phase-in over the next two years for changes to the Home Mortgage Disclosure Act, along comes another change from our friends at government-sponsored entities (GSEs) Fannie Mae and Freddie Mac: a new Uniform Residential Loan Application, or URLA, is here! This form, also commonly known as the 1003, is not explicitly required by federal regulation for mortgage loans, but it is required for any loans that the GSEs purchase and, therefore, is the form most financial institutions use to originate their mortgages. In a cheerful proclamation on their website, the GSEs state, “The first material updates to the URLA in more than 20 years are the result of extensive collaboration. We worked closely with lenders, technology solution providers, mortgage insurers, trade associations, housing advocates, borrower groups, government housing agencies (FHA, HUD, VA and USDA-RD), the Consumer Financial Protection Bureau and other industry participants.” But don’t rush out and start using this amazing new form just yet! The GSEs themselves won’t even accept the new form until January 2018, and if you’re thinking about using it for your portfolio loans before that time, you should know that there are a lot of important ins and outs to consider before adding the new 1003 to your loan document arsenal.
First of all, the good news: The new URLA is a vast improvement format-wise over its predecessor. From a visual standpoint, it has been extensively market-tested and now clearly separates lender information from applicant information, making it easier on the eyes of both creditors and borrowers. Its headings, font and boxes appear extremely similar to the Loan Estimate and Closing Disclosure that are currently required under the TILA/RESPA Integrated Disclosures rule, which should give all the loan file documents a more uniform look overall. Moreover, the form is now dynamic, meaning that its length and content will vary depending on the type of loan being applied for. Unnecessary data fields from the old form have been eliminated. Additionally, both electronic and paper copies of the form will be made available and both will be accepted by the GSEs, accommodating technologically savvy and old-school bankers alike. Finally, the new URLA makes it easier to add and remove additional borrowers than before – this should be a major relief especially to smaller community banks, which in using the older form may struggle to prove to examiners that requirements like establishing joint intent under Regulation B have been met. There are some points of concern with the new form, however. First of all, the form’s dynamic nature means it’s maybe not as consistent as the prior, more universal URLA. What is true for a refinance URLA may not 12
be so for a purchase loan URLA, meaning that identifying the form properly in the course of the loan process and filing it away correctly, especially in the cases where paper copies are used, could become trickier. Secondly, the existing URLA has been around for so long that it is familiar to bankers and is already a firm part of most banks’ lending platforms, so swapping it out with a brand-new form could constitute a major and potentially expensive undertaking, depending on a bank’s particular set-up and costs. (Fortunately, the GSEs are providing a “GMI addendum” that can be tacked onto the old URLA instead of using the new URLA for the early part of 2018, but presumably a full conversion over to the new URLA will be required at some point.) Additionally, although a “final” version of the new form has been put out there, it could be up for a few more tweaks anyway – the CFPB has yet to finish looking at it to ensure it qualifies for “safe harbor” as valid application under Regulation B, and the automated underwriting system with which the new URLA is supposed to function was not expected to be available until late last month. Although the new URLA should be a major improvement once it’s fully up and running, it’s safe to say that the form is nowhere near “ready to rock” yet. The form still needs to be aligned with the GSEs’ automated underwriting and HMDA’s expanded 2018 data collection requirements, and use of the form at this point likely would result in an over-collection of government monitoring information, which runs the risk of violating both Regulation B (ECOA) and Regulation C (HMDA) as they are currently written. Therefore, it’s best to hold off on using the new URLA to originate mortgage loans for the time being. Nevertheless, with all the other big regulatory changes looming on the horizon, financial institutions are encouraged to check out the new form and see how it can best fit into their existing lending platforms. The GSEs have yet to roll out an official launch schedule and training solutions for the form,
resented by
Sponsored by Fourth Quarter 2016 • Connecticut Banking Magazine
but those should be arriving in the near future, so be sure to look out for them. A wonderful FAQ, a summary, copies of URLA forms and addenda and samples of filled-out URLAs for purchase and refinance transactions can be found on the GSEs’ webJANUARY 12, 2017 | MOHEGAN SUN site at www.fanniemae.com/singlefamily/ Presented by Sponsored by uniform-residential-loan-application. (A Spanish version of the form should be availJANUARY 12, 2017 | MOHEGAN SUN able soon as well, if not already.) We’re offering members zero-percent Classic Advances, on a first-come, Presented by Sponsored by I would highly encourage a visit to that first-served basis, to create or preserve jobs in their communities. page for some of the finer details on the new Our new program, Jobs for New England, will award up to $5 million in form, and recommend sticking by Compliinterest-rate subsidies every year through 2018. A maximum of $250,000 ance Alliance for any and all updates regardin subsidy is available per member each year. At current rates, $250,000 ing the GSEs’ implementation of the new can leverage up to $30 million in one-year advances. URLA in 2018 and beyond! To find out more about Jobs for New England, contact Fatima Razzaq at Compliance Alliance offers a wide va617-425-9564, or fatima.razzaq@fhlbboston.com. riety of compliance support resources. To But don’t delay. These funds won’t last forever. learn how to put them to work for your bank, call us at (888) 353-3933 or visit See what your cooperative can do for you! compliancealliance.com. u
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James McGuire has worked as an attorney and legal researcher in the financial industry since 2010.JANUARY He has extensive first-hand experience 12, 2017 | MOHEGAN SUN with Presented openby records, mortgage servicing, consumer law and securities regulation.
Federal Home Loan Bank of Boston • 800 Boylston Street Boston, MA 02199 • www.fhlbboston.com
Sponsored by
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Connecticut Banking Magazine • Fourth Quarter 2016
CFPB Researches and Issues Recommendations on Elder Financial Exploitation By Victoria Stephen
A
t the end of last month, the CPFB released a new report on the “widespread prevalence” of elder financial exploitation. Although it’s likely that only a small number of cases are reported, estimated losses range from $2.9 billion to as high as $36.5 billion each year, in addition to the economic losses suffered by financial institutions and other entities. The report highlights that no single entity can be entirely responsible for preventing and responding to elder abuse and focuses on the role of “networks” in addressing the problem. For this purpose, networks are partnerships or alliances of public and private entities, organizations, and individuals that work to prevent, detect and respond to this type of abuse. The basic conclusion of the research is that networks greatly help combat elder financial exploitation. The CFPB recommends developing and enhancing existing networks and creating new networks in areas where they don’t already exist. While this is more of a long-term solution, it would be worthwhile to review the findings and recommendations in the full report and accompanying resource guide. We’ve been getting more questions about how to respond to elder abuse on an everyday basis, though, so we thought it would be worth backtracking to a corresponding report issued earlier this year on how to detect and take action on elder financial abuse within the bank. These are the six general recommendations and some notable details from the earlier report: 1. Develop, implement and maintain internal protocols and procedures for protecting account holders. • Include training requirements, procedures for making reports, compliance with Reg. E, means of consent for information-sharing with third parties and procedures for collaborating with key stakeholders. • Note that Compliance Alliance has a model Elder Abuse Policy on its website. 2. Train management and staff to prevent, detect and respond. • Include warning signs that may signal financial exploitation, including specific behaviors and transactions that are red flags. 3. Detect exploitation by employing fraud detection systems. • Use predictive analytics and review filtering criteria against individual account holders’ transactional patterns. 4. Report all cases of suspected exploitation to appropriate federal, state and local authorities. • File SARs when required and consider filing them voluntarily in other cases. • Provide documentation quickly and at no charge when requested by Adult Protective Services, law enforcement or other investigating entities.
• Note that reporting, in general, does not violate the GLBA according to guidance issued in 2013. • Consult with counsel and/or your state bankers association on state reporting requirements. 5. Protect older account holders. • Offer age-friendly services that can help protect against financial abuse, like convenience accounts, protective opt-in features and information about planning for incapacity. 6. Collaborate with other stakeholders. • This is where the bank’s participation in network initiatives would come in. The report underscores that banks are “valuable members” of networks and uniquely able to educate on the “nuances of banking policy and procedures.” While the CFPB emphasizes that these are not necessarily requirements, it does go so far as to deem them “best practices,” so it would be advisable for banks to consider them in developing policies and procedures on elder financial exploitation. You can review the details of these recommendations in the full report and supplementary advisory, both available on the CFPB’s website. u Victoria E. Stephen serves as associate general counsel for Compliance Alliance. Stephen has since worked in corporate tax law, mergers and acquisitions, and performed legal research on a range of regulatory issues. 14
Fourth Quarter 2016 • Connecticut Banking Magazine
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Connecticut Banking Magazine • Fourth Quarter 2016
The Compliance Alliance Model By Scott Daugherty
However, in effect, all laws and regulations mandate compliance requirements. If your bank’s compliance model hasn’t been updated to ensure all employees and managers are onboard with this type of compliance culture, now is the time to do that. The theory that compliance belongs to the compliance officer has been completely dispelled as regulators review each area of the bank. Everyone in the bank has a part to play in compliance. While safety and soundness standards continue to have a major role in determining the safety and security of our financial system, consumer and regulatory compliance has begun to be viewed as a top priority in keeping the bank in overall strong health. It is important to keep in mind: • The stretch for yield is already present in many facets of bank operations and lines of business, ranging from pricing to reevaluation of credit standards and consideration of new lines of business that have different profitability and risk tradeoffs. And, as that occurs, we will see boards and senior management searching for new innovative products to increase the bottom line income. • Our economy is more vulnerable to shocks, such as fiscal cliff, natural disasters etc. This volatility challenge raises concerns of another recession, which, in turn, could have a major negative impact on our housing market.
W
hen you start a conversation about compliance within a financial institution, the mindset automatically turns to consumer compliance: those regulations that are issued to protect the rights of the bank’s consumer customers. Even when you search for help with compliance on the internet, or start looking for consultants and auditors for compliance, you will find these services are all geared towards consumer compliance. With at least one exception – Compliance Alliance. Our model of compliance assistance goes well beyond the realm of consumer compliance because we consider all areas of compliance to be in the compliance realm. When Scott Daugherty you look at our model, you will find we have products and services that will be of value to each department and likely each person at your bank. Compliance involves capital requirements, asset quality, allowance for loan and lease losses (ALLL), liquidity and all of the other areas regulators assess during the safety and soundness portion of an examination, including, of course, the typical consumer compliance requirements. We consider all of these areas to be under the umbrella of compliance because they each have guidance, regulations, best practice guidelines as well as other regulatory requirements attached to them. Thus, they are all subject to review to determine if in fact the bank is in compliance with the requirements or guidance. Not only do we consider these to be compliance topics – requiring us to assist our bankers in these areas – we take it even further by providing assistance to directors to ensure they are also well versed and able to have those “compliance” conversations with the examiners. The traditional compliance program has been created to ensure technical compliance with regulations covering specific bank functions. It was not specifically designed to govern compliance in every area and every aspect of the financial institution.
At this point you may be asking: How in the world can the bank address all of these concerns and what exactly are the regulatory expectations? Just as important, how can we as a financial institution make a profit? At Compliance Alliance, we believe this can be accomplished by implementing a compliance framework that is integrated throughout the bank and always keeps in mind the bank's operational view of the risk. Integrating the management of all areas of risk offers tangible benefits. It ensures a comprehensive coverage of risks while facilitating a more efficient allocation of resources and management attention. This model is exactly what we at Compliance Alliance strive to provide for our member banks. We provide a staff of attorneys and compliance specialists (who all have banking backgrounds) to assist our members by providing them with an entire lineup of toolkits and hotline services to give them the opportunity to be bankers. Compliance Alliance offers a wide variety of compliance support solutions. To learn how to put them to work for your bank, call us at (888) 353-3933 or visit compliancealliance.com. u Scott Daugherty is the president and general counsel for Compliance Alliance, Inc. Prior to Compliance Alliance, he joined the legal staff of the Texas Bankers Association in 2003, serving as the primary contact for the legal and compliance hotline, while also tackling legislative issues. He is one of the leading bank regulatory, compliance and legal experts in the nation. 16
Fourth Quarter 2016 • Connecticut Banking Magazine
Dodd-Frank’s Price Tag By Rob Nichols
T
he president’s Council of Economic Advisers seems to have taken to heart Mark Twain’s suggestion to “get your facts first, then you can distort them as you please.” A report from the group released in August reviews the aggregate performance of community banks then boldly – and illogically – concludes that the Dodd-Frank Act has not harmed that segment. Specifically, the report claims that bank branching patterns, lending growth and geographic reach “show that community banks remain strong.” The statement is jaw-dropping in its willful disregard for the true cause and effect of the disappearance of 1,708 banks – or 22 percent of the industry – since the enactment of Dodd-Frank in 2010. It’s as if the White House is saying “what does it matter if we are losing a bank a day, there are others around that can lend.” We know how much it matters – to you and to the communities that no longer have their local hometown bank. And we know that it is more than just market forces and “macroeconomic conditions” that are driving the twin trends of bank consolidation and the dearth of new bank charters. As I said in a letter to the CEA respectfully challenging its conclusions, the thousands of pages of new regulations that have been imposed on community banks in recent years is an enormous driver of decisions to sell to a larger bank. Those same regulations are restricting product offerings, like mortgages, and discouraging banks from growing for fear of the increased regulation that is triggered by crossing an arbitrary asset threshold. This leaves customers with fewer choices and communities with less service. Complex, ill-fitting rules – from DoddFrank and beyond – are also to blame for the lack of de novos in recent years. The CEA suggests the real reason is low interest rates, but large numbers of new banks have formed in past recessionary times, so that argument just doesn’t wash. The CEA’s conclusions, in short, feel forced and out of touch. Had the researchers called real, live bankers who are grap-
pling with how to grow their business in the current regulatory environment, they could have gotten right to the heart of the matter. They might have heard something like this, taken from a note that one of ABA’s members recently sent explaining his bank’s decision to hang it up: Unfortunately we became a victim of Dodd-Frank. The effects of Dodd-Frank – plus other regulatory issues – resulted in financial projections showing substantial declines in revenues and increases in compliance costs, reaching the point that in a few short years an otherwise healthy community bank with strong capital and satisfactory earnings could no longer meet a number of financial bench-marks set by the regulators. These conclusions forced the bank to sell now when our shareholders and some of our employees would be less adversely affected. When this bank merged with a larger one, half of its employees lost their jobs.
And that highlights yet another costly toll of government-induced consolidation: the lost contributions of men and women who play leading roles in their communities. John Ikard, last year’s ABA chairman, said it well in his farewell speech at our convention. A community can lose their bar or their grocery store, but they can’t lose their bank, adding that online lenders are no replacement. “You can’t go online to get a leader. Banks don’t just provide money. They provide the people who serve on the school board, United Way, churches.” That kind of involvement – which undoubtedly makes communities richer – is not something any economist can put a value on. u Rob Nichols is president and CEO of the American Bankers Association. Email him at nichols@aba.com.
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Connecticut Banking Magazine • Fourth Quarter 2016
Ann Mitrione
Zac Collins
Raymond Michaud
Elizabeth Gore
Janice Ward
Carolyn Welch
Bernadette Jones
Gregory Shook
Irene Ropicki
Laura Silver
Jagjiwan Singh
Hugo Ramirez
Steven Ferguson
Bruce Blasnik
David Cingari
Vincent Vetrini
Bridget Reardon
Jeff Hubbard
Peter Keller
David Cantor
Steven Hoffman
Arthur Rhatigan
David Baker
Miranda RonkeCzarniecki
Michael Muldoon
Martha Burgess
Douglas MacLean
James A. Mengacci
Carl Bartolotta
Thomas Simmons
Bankwell announced Ann Mitrione was named to the board of directors of the Trackside Teen Center. Zac Collins joined the bank as vice president and commercial and industrial lender; and Raymond Michaud was named assistant vice president and residential mortgage sales manager. Berkshire Bank, CBT Region announced Elizabeth Gore was promoted to senior vice president of trust operations and compliance and Janice Ward was promoted to senior vice president, wealth advisor and senior fiduciary officer. Chelsea Groton Bank announced Carolyn Welch joined as vice president and commercial loan officer. Essex Savings Bank announced Robert Paolucci and Patrick Gingras were appointed to the board of directors; Lynda Hunnicutt was recognized as an “Outstanding Volunteer” by Middlesex County Community Foundation; Rose McLaughlin was re-elected as secretary to the Madison Chamber of Commerce; Bernadette Jones was recognized as an “Unsung Hero” by Middlesex County Community Foundation and Gregory Shook was elected chairman to the Middlesex County Chamber of Commerce. Fairfield County Bank announced Irene
Ropicki was promoted to vice president of retail lending operations; Catherine W. Frierson was elected as corporator to the board; Laura Silver was promoted to associate vice president and marketing manager. First County Bank announced Jagjiwan Singh joined as assistant vice president and business development officer; Hugo Ramirez joined as assistant vice president and branch manager; Steven Ferguson was named as one of Fairfield County’s 40 Under 40; and Bruce Blasnik, David Cingari, and Vincent Vetrini were named corporators to the board. First National Bank of Suffield announced Janet Frechette and Brendan Begley were named to the board of directors. Ion Bank announced Bridget Reardon joined as personal lines account manager. Key Bank named its executive leadership team: Jeff Hubbard, market president; Peter Keller, private banking sales leader; David Cantor, business banking sales leader; Steven Hoffman, business banking sales leader; Arthur Rhatigan, commercial banking sales leader; David Baker, mortgage lending regional sales leader; Miranda RonkeCzarniecki, mortgage sales leader; Michael Muldoon, mortgage sales leader; Martha 18
Burgess, area retail leader; Mary Ann Ludtke, area retail leader; Carole Ibsen, area retail leader; Janice Yusza, area retail leader; Ken Raskin, area retail leader; and Douglas MacLean, team leader. Liberty Bank announced James A. Mengacci was elected to the Liberty Bank Foundation board of directors; Carl Bartolotta, a CSFM graduate, was appointed vice president of business information services; Thomas Simmons was appointed vendor management officer; Kurt Johnson was appointed vice president and residential sales manager; and Lucinda Prigionieri was appointed vice president of retail banking. Newtown Savings Bank announced Richard Barredo joined as vice president and commercial loan officer; Mark Candido joined as regional director of commercial lending; and Anthony Rossley joined as vice president of commercial loan officer. Salisbury Bank & Trust announced Brooke Morehouse received the Rookie of the Year Award; Gary Cope received the Employee of the Year Award; Julianna Sinchak graduated from the American Bankers Association School of Bank Marketing and Management; Robert Drucker announced his retirement as a director; Amanda Lidstone attained the Certified AML and Fraud Professional
Fourth Quarter 2016 • Connecticut Banking Magazine
Kurt Johnson
Lucinda Prigionieri
Richard Barredo
Mark Candido
Anthony Rossley
Brooke Morehouse
Gary Cope
Julianna Sinchak
Amanda Lidstone
Jessica White
Peter Sepelak
Spring Burke
Kimberly Downey
Steve Essex
Michele LaPlante
Martin Morgado
Adlai Richards
Savoeun Buck
Alon Sapir
Jennifer Saladin
Scott Heimer
Emily Petrik
Gene Michael Deary
Eric Bennett
Allison Nuhfer
Nicole Corcoran
Jennifer LaBianca
Sharon McHugh
Trevor Wood
Laurie Gervais
Melissa Brodack
Robin DiNicola
Stephen Siguenza
Melanie Joy
Michael Sciamanna
Kim Ramchandani
Carolyn Morrison
John Tracey
Todd Purcell
Lisa Casper
Lawrence Davis
accreditation; Jessica White received the 2015 President’s Award; Peter Sepelak was hired as assistant vice president and branch manager; Spring Burke was selected as a top mortgage professional for 2016 by Top Agent Magazine; Jean Stapf was promoted to assistant vice president and trust administrative coordinator; Kimberly Downey was promoted to vice president and trust officer; Steve Essex was promoted to executive vice president and head of trust wealth advisory services; and Michele LaPlante received the Volunteer of the Year Award. Savings Bank of Danbury announced Martin Morgado was promoted to bank president and CEO; Adlai Richards joined as mortgage administrator; Savoeun Buck was promoted to officer and branch manager; Alon Sapir joined as assistant vice president and licensed relationship development officer. Savings Institute Bank & Trust announced Jennifer Saladin was promoted to operations officer; Scott Heimer joined as locations
manager; Emily Petrik joined as branch manager; Gene Michael Deary was honored with the Outstanding Leadership Award from the Connecticut Rivers Council, Boy Scouts of America; Eric Bennett was promoted to branch officer; Allison Nuhfer was promoted to operations officer; Nicole Corcoran was promoted to assistant treasurer; Jennifer LaBianca, Sharon McHugh and Trevor Wood were promoted to assistant vice president; Gene Michael Deary was promoted to senior vice president; Laurie Gervais was chosen as a 2016 Women of FIRE winner; and Melissa Brodack joined as mortgage consultant. Simsbury Bank announced Robin DiNicola was awarded the Loren Bristol Spirit Award by the Avon Chamber of Commerce. Start Community Bank announced Patricia Scussel was elected secretary of the Whalley Avenue Special Services board of commissioners and Maureen Frank joined the board of directors for Clifford W. Beers Guidance Clinic. Union Savings Bank announced Patty Dyer was chosen as a 2016 Women of FIRE winner; Stephen Siguenza was promoted to business banking officer; and Geralyn Hatcher joined 19
as assistant branch manager and retail banking officer. United Bank announced Melanie Joy was chosen as a 2016 Women of FIRE winner. Webster Bank, N.A. announced Michael Sciamanna was named to the Fairfield County Business Journal’s 40 Under 40 Award list for 2016; Kim Ramchandani was promoted to senior vice president and financial advisor; Carolyn Morrison was named a board member of the Connecticut Power and Energy Society; John Tracey joined as managing director and senior relationship manager for the Commercial Bank’s Sponsor and Specialty Finance group; Jason Giordano, Kathy Hanson and David Nastri were promoted to senior vice president of Webster Investment Services; Todd Purcell joined as senior vice president and director of digital marketing; Walter Squires and Carol Tartaglia were promoted to senior vice president and financial advisor; Lisa Casper was chosen as a 2016 Women of FIRE winner; and Lawrence Davis was promoted to senior vice president and senior relationship manager of commercial banking. u
Connecticut Banking Magazine • Fourth Quarter 2016
Essex Savings Bank will be donating $110,000 to local nonprofits throughout the year. Essex Savings Bank recognized World Elder Abuse Awareness Day.
Bank of America employees volunteered to take disabled veterans fishing.
Bankwell sponsored the 19th Annual Habitat 5K Run for Home & WorkBoot Challenge.
Farmington Bank opened a new branch office and held a monthlong grand-opening celebration.
Berkshire Bank joined CRA Partners to support Senior Crimestoppers program. Berkshire Bank offered free admission to Hancock Shaker Village for children ages 12 and under. Berkshire Bank Foundation Scholarship Awards Program awarded $45,000 to 30 high school seniors. Bank of America employees completed a peanut butter and jelly drive for South Park Inn.
Berkshire Bank recognized 31 employees and named three “top volunteers” through their Volunteer Service X-ellence Awards program. Each top award winner received a $1,000 donation to be made on behalf of the nonprofit organization of their choice. Berkshire Bank donated $2,100 to 22 nonprofits as part of Xtraordinary Day of Service and the “Catch Us in the Act” photo contest.
The Bank of America Student Leaders program provided Hartford students with a paid summer internship and leadership training in Washington, D.C.
First County Bank donated school supplies totaling $2,760.
First County Bank celebrated the opening of its new branch with a ribbon-cutting ceremony.
Berkshire Bank employees donated over 4,500 hours supporting more than 100,000 people in their communities. Berkshire Bank sponsored Six Flags New England with a Laser Light Show Giveaway. Berkshire Bank’s Charitable Foundation awarded $1,120,862 in grants to nonprofit organizations.
The First County Bank Foundation awarded three high school seniors the Richard E. Taber Citizenship Award Scholarship.
Chelsea Groton Foundation awarded $94,550 in grants to 59 nonprofit organizations.
Bank of America employees volunteered to stuff backpacks with school supplies for Hartford school children.
Chelsea Groton Bank produced and sponsored a number of financial literacy seminars to educate members of the community on improving credit scores, home-buying, budgeting and preventing identity theft.
First County Bank was the presenting sponsor of the 2016 Norwalk Seaport Association’s Oyster Festival.
Dime Bank Foundation awarded $1,500 to Rose City Senior Center. Dime Bank Foundation awarded $4,000 to New London Homeless Hospitality Center.
Bankwell partnered with Clifford Beers Clinic supporting the “Backpack Drive, Let’s Get Packing” drive.
Dime Bank Foundation awarded $2,500 to Norwich Youth and Family Services. Dime Bank sponsored the Secor Volvo Fishers Island Sound Race.
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The First National Bank of Suffield collected nonperishable food and other items for the Suffield Emergency Aid Associations Food Pantry.
Fourth Quarter 2016 • Connecticut Banking Magazine
First Niagara donated $10,000 to the University of New Haven in support of its Nonprofit Institute and its Shared Live Client Experience program.
Liberty Bank presented a $2,000 Youth in Action award which was donated to several nonprofits. The Milford Bank hosted its Second Annual Milford Moves 5K raising $8,000 for veterans. The Milford Bank held its third Blood Drive. The Milford Bank sponsored a drive for the Rape Crisis Center collecting items for their victim support packages.
First Niagara donated $6,000 to Fairfield University in support of its Workforce Readiness Assistance program.
The Milford Bank held its Second Annual Green Fair.
Savings Bank of Danbury and Stamford Mortgage Co. employees donated 13 backpacks filled with school supplies and three gift cards through the United Way Workplace Volunteer Council.
Ion Bank Foundation awarded $39,700 in grants to eight area nonprofit organizations. Ion Bank hosted a Cyber Security Seminar for business customers. Newtown Savings Bank celebrated the opening of New Haven Regional Lending Center with an official ribbon-cutting ceremony.
Savings Institute Bank & Trust’s 100 Percent Employee Funding Caring & Giving Program presented checks to various agencies totaling over $2,500 during the second quarter 2016.
Jewett City Savings Bank took part in the festivities at Youthtopia. Salisbury Bank was a sponsor at the Taste of the Tri-State held by the Tri-State Chamber of Commerce.
Jewett City Savings Bank participated in the Eastern Connecticut Relay for Life raising over $6,000 for the American Cancer Society. Salisbury Bank held several successful Community Shred Days with thousands of pounds of paper shredded and recycled.
Savings Institute Group Foundation Inc. presented a $3,500 grant to Covenant Soup Kitchen.
Savings Institute Group Foundation Inc. presented a $2,000 grant to Horses Healing Humans.
Salisbury Bank offered tips for protecting mobile devices for National Consumer Protection Week. Salisbury Bank offered a free seminar on the basics of Medicare. Liberty Bank cut the ribbon on a newly-renovated branch.
Salisbury Bank offered tips to prevent tax id fraud during Tax Identity Theft Awareness Week.
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Savings Institute Group Foundation Inc. presented a $2,000 grant to the Boys and Girls Club of Newport County.
Connecticut Banking Magazine • Fourth Quarter 2016
Union Savings Bank celebrated their 150th anniversary with the community at a CityCenter Danbury Summer Concert.
Savings Institute Bank & Trust recently contributed $3,800 to The Last Green Valley Inc. to support the nonprofit’s annual Walktober and Tastes of the Valley events.
Simsbury Bank was a $5,000 sponsor of the Pillar Community Development Corp.’s Annual Golf for Educational Excellence.
United Bank presented a check for $1,250 to the Hamden/North Haven YMCA.
Savings Institute Foundation presented $32,000 in grants to Connecticut organizations. Savings Institute Bank & Trust was honored with an award from Flo-Tech for their commitment to sustainability.
Start Community Bank participated in a Back-toSchool drive for children at Clifford W. Beers Guidance Clinic.
Torrington Savings Bank was the presenting sponsor for Prime Time House Golf Fundraiser.
United Bank presented a $20,000 check to the Aurora Foundation.
United Bank presented a $25,000 check to the Hartford Marathon Foundation.
Simsbury Bank opened a new branch with a ribbon cutting.
Torrington Savings Bank awarded two $10,000 scholarships to recent high school graduates.
Simsbury Bank announced two winners of their contest at Celebrate West Hartford.
United Bank presented a $5,000 donation to the Town of Vernon for the 2016 “July in the Sky Fireworks.”
Union Savings Bank hosted an inaugural Summer Reading Book Drive collecting over 600 books.
Webster Bank received the Partner in Business award from CCARC, Supporting People With Disabilities.
Union Savings Bank celebrated a fifth anniversary at one of their branches with the community.
Webster Bank awarded a total of $80,000 to nonprofit organizations.
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