What I Learned at the ABA's RCC
By David Dickinson
I recently attend the American Banker Association's Regulatory Compliance Conference (ABA RCC) in Chicago along with 1200 other compliance professionals. I had the honor of speaking on the topic of Flood Insurance on a panel with representatives from the NFIP and the FDIC, along with two bankers. Over the next few weeks, I'll be giving you some notes from some of the sessions I attended.
The first session was called the "State of the Union". We, at Banker's Compliance Consulting, are always trying to stay on top of the regulatory issues, hot topics and new releases. This session really scared me when they began listing all the issues we face or are about to face. Here's a short list:
- Reg Z - High Cost Mortgage proposal. Expect the final to be issued in July.
- Lots of other proposals and changes coming:
- RESPA (I really hope this one doesn't happen!);
- Flood FAQs (hopefully, we'll see the final FAQs by the end of the year);
- FACT Act - 2 final (ID Theft and Address Discrepancy) and 1 proposal concerning the Risk Based Pricing Notice;
- 2 Truth in Lending proposals in process;
- UDAP (most concerning overdrafts); and
- Reg DD (mostly concerning overdrafts).
On top of all this, the speakers indicated, there are more regulations & guidance likely to be coming from Congress. With the current mortgage "crisis", Congress feels they need to get more involved in the regulatory process. They are more than concerned with several issues like Predatory Lending and Broker licensing and regulating. While I agree there are a few bad apples out there that need to be reigned in, I don't believe more regulations will improve our industry or protect the victimized. In fact, the more disclosures we give, the less the "protected" will read. Hence, the effect is "more is less".
We (that means YOU) need to write comment letters and talk to our Congressional Representatives. Help them understand your perspective so they are more informed instead of just hearing from the few victims.