Independent Banker - December 2017 - 68

Risks & Rules
basis, " Gaskill says, " but we now
meet monthly to stay abreast of and
be involved in all of the regulatory
changes, policy revisions, compliance
monitoring and risk assessments.
We've also added annual outside
compliance reviews to enhance compliance
oversight. "
Bedsole, too, has made compliance
management changes at BankSouth.
" We have added a senior compliance
analyst in our mortgage banking
subsidiary to help deal with the
expansion of our third-party origination
channel and other concerns, " he
says. " We've also widened the use of a
specialized software platform to gain
efficiencies on managing compliance. "
In 2017, compliance examinations
" We have added a senior compliance analyst in our
mortgage banking subsidiary to help deal with the
expansion of our third-party origination channel
and other concerns. "
-JIM BEDSOLE, BANKSOUTH
shifted from a primarily transactionbased
methodology to one that is
focused on risk management. The
new, risk-based ratings system took
effect on March 31, 2017, replacing a
system that was established in 1980.
Exams
At the time of this writing, First
State Bank was scheduled for an
FDIC compliance examination.
Grooms believes the FDIC did a
good job of explaining the process
and says his peers in the community
bank's monthly compliance group
calls agree.
" The examiners used to touch
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every area of compliance but on a
rotation over the years, " Grooms
explains. This year, " they sent
a robust, high-level request for
information early on and used it to
conduct their own risk assessment,
then created a follow-up request for
more information. According to the
examiners, the new process allows
them to more narrowly focus on the
areas of risk they wish to review, and
it allows them to greatly reduce the
time they spend on-site in the bank. "
BankSouth was scheduled for an
Office of the Comptroller of the Currency
(OCC) compliance examination
and a separate examination for TRID
compliance in 2017. Employees
were notified that the community
bank would be scheduled for a Fair
Lending Risk Assessment, because
it exceeds $500 million in assets.
According to the OCC, the assessment
will be conducted in any year in
which the bank does not undergo a
full-scope fair-lending exam.
Despite this year's mortgage
compliance whirlwind, community
bankers took a deep breath and
faced the technical and managerial
compliance challenges of 2017. It
is a practice with which they have
become well acquainted.
Mary Thorson Wright, a former
Federal Reserve examiner, is a financial
writer in Virginia.
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Independent Banker - December 2017

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