[Anonymous]

I have reviewed the material from last Friday’s meeting on UDAAP. I thought the policy was fine as printed and just plugged internal bank names where needed to meet the responsibilities. It is ready to be approved at our board meeting next month. I have printed off the procedures and checklists for each section and given a copy to our President, Operations Oficer and Internal Auditor to review and we are going to discuss next week. I liked the format and the checklists pretty well as printed but will have more feedback after our meeting.

Thanks,
Glenn Vick
Auburn Banking Company

[Anonymous]

I’m going to get into the “heavy lifting” of UDAAP tomorrow – I’ve been finishing a project this week. With that said, I thought I’d go ahead and at least try to get a thread started.

I’m not certain what Jack had in mind for this thread, but I think the most important thing on my to-do list will be reviewing disclosures – though I’m trying to get a feel for who I’ll get to review the disclosures. My general thought is that less experienced employees may be good “volunteers” for this job as they won’t have the experience to “know what it meant”.

I shall return.

[kowsley]

I have done a quick review of the UDAAP information that Jack provided to us in the last webinar and I am really struggling with the best option of how to complete procedures. On the one hand, it would be great to have them broken down by product/service; however, I think this would be a monster procedure for our bank if that were to happen. It may make more sense in our case to break it down by department but then I am concerned that I will overlook something. Anyone else have any thoughts? We do not have a policy or procedure currently in place for UDAAP and this is going to be on my radar for the first quarter of 2012.

[jholzknecht]

I spent the past two days as part of the panel at the BankersonLine.com annual Lending Compliance Triage Conference in Louisville. We had two long days of presentations and discussions. We had about 50 banks with us at the meeting site, but we had about 200 banks (probably around 1,000 bankers) participating remotely.

We worked hard during the day and had two enjoyable evenings together. On Monday night, Patti and I had a backyard cookout for the BOL staff, the other presenters, and the BOL Queens. We had a perfect fall evening for outdoor entertaining next to the lake. On Tuesday evening we gathered at Michele Petry’s (one of the BOL founders) house for dinner, music and signing.

We covered over 30 topics during the two days, but the top two topics were Fair Lending and UDAAP. Both issues have been on the rise over the last few years and are getting a lot of attention from examiners. The Dodd-Frank Act is expanding the regulatory burden for each of these topics. You will hear much more about each in the years to come.