pictured left to right: Assistant Deputy Commissioner Jeff Bagby, Deputy Commissioner Dudley Gilbert, Assistant Deputy Commissioner Wayne Arbuthnot
Deputy Commissioner Dudley Gilbert recently
attended the annual Legal Seminar hosted by the Conference of State Bank
Supervisors. This year’s Legal Seminar
was attended by agency counsel from 29 states, the District of Columbia, and
attorneys representing the FDIC and Federal Reserve Bank. The program included numerous presentations
and discussions, including a status update on the lawsuit filed by CSBS against
the Comptroller of the Currency in connection with the OCC’s proposal for a
non-bank charter for “fintech” companies.
There was also a docket review of litigation around the country relating
to financial institutions and their regulators.
The attorneys then reviewed the Interstate Cooperative Agreement entered
into among all the state banking departments that enables seamless supervision
of banks operating in an interstate environment.
CSBS also scheduled a Deputy Conference to overlap
with the final day of the Legal Seminar. Assistant Deputy Commissioners Wayne
Arbuthnot and Jeff Bagby from the Oklahoma Banking Department joined deputy
commissioners from 25 other states in attendance at the Deputy Conference. During the overlapping session, the deputy
commissioners and attorneys heard from Paul Cummings, a retired special agent
with the Department of Homeland Security. Mr. Cummings described how his work in Texas
relied significantly on suspicious activity reports filed by bankers. He explained how he would start and build a
case against large money laundering and drug operations by reviewing SARs filed
against individuals that otherwise had no criminal record. He stressed how important it is to file the
SARs even though the banking community often questioned whether the SARs were
monitored or acted on by law enforcement.
The Deputy Conference provided the attendees an
opportunity to discuss various supervisory initiatives directly with the
representatives from the FDIC and Federal Reserve Bank. The deputy
commissioners also heard from CSBS regarding proposed changes and improvements
to the accreditation program for member agencies as well as the Examination
Tools Suite (ETS) utilized by examiners in their preparation of an exam report.
Examiner Mo Wilson completed the first year of the Graduate School of Banking at Colorado three-year curriculum in July. The first week of the two-week agenda consisted of
intense study of Bank Financial Analysis, Asset/Liability Management,
Fundamental of Leadership and Economics for Community Bankers which included a case
study of assessing a bank performance and implementation of strategies of
improvement for the case study bank.
second week focused on courses of Marketing Financial Services, Navigating the
Regulatory Environment, Effective Use of Technology and Business Law in
Financial Institutions. Wilson will be required
to complete three projects - comprised of Asset/Liability Management, Bank Financial Analysis and Current Issues/internet Services - prior to the commencement of next year’s two-week session. These projects will be 12-15 page reports due
throughout the year.
The 2017 GSBC session was attended by over 500 bankers and regulators
across the United States. Oklahoma was well-represented
with the most attendees outside of Colorado, the host state. The School is designed to emphasize community
banking by developing future leaders in banking as well as networking opportunities
with colleagues in the industry.
Senior Examiner Daryl Jones attended the Cannon Financial
Institute’s Trust Audit, Compliance and Risk Management I School in July. The five day
school included attendees from 12 states and Puerto Rico with a mix of
regulators, bankers, and trust company employees. The topics covered were: laws
and regulations: property laws, conflicts of interest, transfer taxes, probate
administration, powers of appointment and various types of different trust and appropriate
planning of those trusts.
Senior Examiner Gwen Wright recently attended the 2017 ProBank Austin Anti-Money Laundering and Bank Secrecy Act Two-Day Seminar presented by Mark W. Denver. The two-day school covered in detail the issues regarding the
ever-expanding environment of the Bank Secrecy Act. Day one covered the “Basics” which included:
Regulatory Requirements, Enforcement Actions, USA PATRIOT Act, Currency
Transaction Reporting, Suspicious Activity Reporting, Recordkeeping, and Office
of Foreign Assets Control (OFAC). Day
two covered the latest regulatory changes and updates from FinCEN and the
regulatory agencies. A few of the
updates included: Implementing the Beneficial Ownership/Customer Due Diligence
program, Third-Party Payment Processors, ACHs, Cyber-Related Events, E-Mail
Compromise Fraud, and Marijuana Banking.
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