2014 Vol. 98 No. 4

30 HќќѠіђџȱ юћјђџ ѝџіљȱ2014 The Dodd–Frank Wall Street Reform and Consumer Protection Act, more commonly known as the Dodd-Frank Act, was signed into law ‹¢ȱ ›Žœ’Ž—ȱ Š›ŠŒ”ȱ ‹Š–Šȱ˜—ȱ ž•¢ȱ 21, 2010. When all is said and done, it will have brought the most sweeping changes to regulation of the U.S. industry since the reforms enacted after the Great Depression. ȱ œȱŒ˜–™•’Š—ŒŽȱ˜ĜŒŽ›œǰȱ Žȱ‘ŠŸŽȱ known that massive new mortgage regulations were coming since we ꛜȱ‘ŽŠ›ȱŠ‹˜žȱ‘Žȱ ˜Ȭ ›Š—”ȱ Act, but were not certain when they would arrive. Meantime it has been quite a waiting game. This legislation brought the possible necessity of creating vast amounts of new policies and procedures, as well as some –Š“˜›ȱŠ—ȱ–’—˜›ȱŒ‘Š—Žœȱ˜ȱ–Š—¢ȱ already established policies and procedures. For me, even with more than 20 years of banking experience, I can honestly say I never would have imagined (nor had I seen) so many changes occurring at the same time from a single piece of legislation. Yet with my experience and focus on detail, I felt I was up for the challenge. Once the Consumer Financial Protection Bureau (CFPB) posted the ꗊ•ȱ›ž•Žœȱ˜ȱ–Š—¢ȱ˜ȱ‘Žȱ—Ž ȱ–˜›- ŠŽȱŒ‘Š—Žœȱ’—ȱ Š—žŠ›¢ȱŘŖŗřǰȱ ȱ™žȱ away all of my other secondary reading material and made Dodd-Frank my new novel to complete. Reading it once through was not enough. I felt the need to break it down and began to separate the various sections and contemplate which ones would ulti- –ŠŽ•¢ȱŠěŽŒȱ–¢ȱŒ˜––ž—’¢ȱ‹Š—”ǯȱ ’Ĵ•Žȱ’ȱ ȱ”—˜ ȱ‘Šȱ‘’œȱŒ˜••ŽŒ’˜—ȱ of mortgage changes would require more action than any past regulatory change. When past regulation changes ‘’ǰȱ’ȱ ˜ž•ȱ‘ŠŸŽȱ‹ŽŽ—ȱœžĜŒ’Ž—ȱ˜ȱ read the Federal Register, study the Œ˜––Ž—Š›¢ȱŠ—ȱ™˜œœ’‹•¢ȱŠĴŽ—ȱŠȱ seminar. With the volume of DoddFrank changes that have been placed in our hands in a brief time span, and more still to come, I knew the processes I had followed in the past were —˜ȱ˜’—ȱ˜ȱ‹ŽȱœžĜŒ’Ž—ȱ˜ȱž••¢ȱ understand and comprehend the actual meaning behind some of the requirements. To fully comprehend the magnitude of these new mortgage changes, it became necessary ˜ȱŠĴŽ—ȱœŽ–’—Š›œǰȱœž¢ȱ–Š—žŠ•œǰȱ review mortgage compliance articles and involve myself in mortgage discussion groups. ȱ ™˜—ȱŽĴ’—ȱ’—˜ȱ‘Žȱ‘ŽŠ›ȱ˜ȱ some of the changes, I realized they were unlike anything I had ever seen or dealt with in the past. Within each of the various mortgage changes came a subsequent amount of additional changes that we needed to make to our established policies and procedures. Preparing for Change ȱꗍȱ–¢œŽ•ȱ‘Š—”ž•ȱ˜›ȱ‘Žȱ›Ž- œ˜ž›ŒŽœȱ‘Šȱ‘ŠŸŽȱ‹ŽŽ—ȱŠ••˜ĴŽȱ˜ȱ‘’œȱ Œ˜–™•’Š—ŒŽȱ˜ĜŒŽ›ǯȱ ’‘ȱ‘Žȱ–Š- nitude and challenges of these new mortgage changes, only one resource would not have been enough to sift through everything the CFPB gave žœȱ’—ȱ Š—žŠ›¢ȱŘŖŗřȱŠ—ȱœž‹œŽšžŽ—ȱ months. The amount of detail in the regulation changes has required repetitive analysis, review and discussions. During these times of discussion Š—ȱ›ŽŸ’Ž ȱ ’‘ȱ–¢ȱ™ŽŽ›œǰȱ ŽȂŸŽȱ utilized many helpful resources including blogs, articles, training and regulation tracking from the CFPB, Indiana Bankers Association, American Bankers Association and Independent Community Bankers of America, to name a few. To ensure my bank would be ready to implement these changes ‹¢ȱ‘ŽȱœŠ›ȱ˜ȱŘŖŗŚǰȱ ȱꛜȱ‹ŽŠ—ȱ reading the possible changes that ˜ž•ȱ™˜Ž—’Š••¢ȱ‹Žȱꗊ•’£Žȱ’—ȱ 2013. I analyzed how the regulation Œ‘Š—Žœȱ ˜ž•ȱŠěŽŒȱ–¢ȱ‹Š—”ǰȱ‘Žȱ risk involved with each choice made, Š—ȱ”Ž¢ȱ™•Š¢Ž›œȱŠěŽŒŽȱ‹¢ȱŽŠŒ‘ȱ˜ȱ these changes. My board of directors and compli- Š—ŒŽȱŒ˜––’ĴŽŽȱ—˜’ęŒŠ’˜—œȱŠŒžŠ••¢ȱ began more than two years ago with an executive summary of the mortgage lending changes potentially approaching on the compliance horiRamping Up for the New Mortgage Rules яќѢѡȱѡѕђȱ Ѣѡѕќџ ——ŽĴŽȱ ž›˜—ȱ’œȱŒ˜–™•’Š—ŒŽȱ˜ĜŒŽ›ǰȱ Š—”ȱ ŽŒ›ŽŒ¢ȱ ŒȱŠ—ȱ ˜––ž—’¢ȱ Ž’—ŸŽœ–Ž—ȱ Œȱ˜ĜŒŽ›ȱŠȱ Farmers State Bank, LaGrangeǯȱ ȱŒŽ›’ꮍȱ›Žž•Š˜›¢ȱ compliance manager, she has been in banking for 22 years and in compliance for eight years. Curton serves on the Indiana Bankers Association ˜–™•’Š—ŒŽȱ ˜––’ĴŽŽǰȱ‘Žȱ —’Š—Šȱ ˜›ŠŽȱ Banking Association Working Group and the Federal Registration Institution Working Group of the ˜—Ž›Ž—ŒŽȱ˜ȱ ŠŽȱ Š—”ȱ ž™Ž›Ÿ’œ˜›œǯȱ ‘ŽȱŠĴŽ—Žȱ Š”•Š—ȱ ˜––ž—’¢ȱ ˜••ŽŽȱŠ—ȱ’œȱŠȱ›ŠžŠŽȱ˜ȱ‘Žȱ —œ’žŽȱ˜ȱ Ž›’ꮍȱ Š—”Ž›œǯȱ ‘ŽȱŠž‘˜›ȱ can be reached at 260-350-6025, email: acurton@gofsb.com. Farmers State Bank, LaGrange, is an IBA-member bank. DIRECTORS / SENIOR MANAGEMENT

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