On July 16, 2018 the Federal Emergency Management Agency (FEMA) proposed revisions to its flood regulations. FEMA proposes to amend parts 59, 61, and 62 of 44 CFR. These parts contain regulations implementing the NFIP. In addition, FEMA proposes to amend Appendices A(1) – A(3) of part 61, containing the three forms of the SFIP: The Dwelling Policy Form, the General Property Form, and the Residential Condominium Building Association Form.

FEMA proposes this rulemaking for three purposes.

• First, it intends to make several non-substantive changes designed to improve the readability, uniformity, and clarity of the NFIP regulations.
• Second, FEMA proposes to make several non-substantive updates to regulations to align with the requirements of Biggert-Waters Flood Insurance Reform Act (BW Act) and Homeowner Flood Insurance Affordability Act (HFIAA).
• Third, FEMA proposes two substantive, albeit minimally so, changes to its regulations codifying the requirements of BW Act and HFIAA.

Please understand these are not the flood regulations issued by the prudential bank regulatory agencies that directly impact flood insurance compliance. The proposal impact FEMA regulations that indirectly impacts your flood compliance efforts.

A copy of the 60-page proposal is available at:  https://www.gpo.gov/fdsys/pkg/FR-2018-07-16/pdf/2018-13292.pdf

 On June 25, the Board of Governors of the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (the agencies) announced the availability of the 2018 list of distressed or underserved nonmetropolitan middle-income geographies, where revitalization or stabilization activities are eligible to receive Community Reinvestment Act (CRA) consideration under the community development definition. The agencies apply a one-year lag period for geographies that were listed in 2017 but are no longer designated as distressed or underserved in the current release. Revitalization or stabilization activities in these geographies are eligible to receive CRA consideration under the community development definition for 12 months after publication of the current list.

The 123-page list is available at: https://www.fdic.gov/news/news/press/2018/pr18038.pdf

Recently a member of our Compliance Masters Group inquired, “It looks like the CFPB has dropped their case with Zillow according to a statement by Zillow.  We had a lot of our lenders wanting to co-market with realtors on Zillow.  Now what?”

Good question.

What we do know – Zillow Group received a letter from the CFPB on June 22 stating that the CFPB “had completed its investigation, that it did not intend to take enforcement action, and that the Company was relieved from the document-retention obligations required by the Bureau’s investigation.”

What is not clear – What were the CFPB’s concerns with Zillow Group’s co-marketing program? What adjustments did Zillow make to eliminate the CFPB’s concerns? If Zillow did not make adjustments, why was the investigation terminated?

What we need – Guidance from the CFPB explaining how to set up a co-marketing arrangement that fully complies with Section 8 of the Real Estate Settlement Procedures Act would be a good start.

CFPB’s investigation placed a stain on Zillow. Some lenders have avoided entering arrangements with Zillow because of fears of getting caught up in the investigation. Now the investigation has ended. It is unlikely that the CFPB will issue an “all-clear” announcement that it is safe to do business with Zillow or to issue clarifying guidance any time soon.

Now What? – Anyone in an arrangement with Zillow should be more comfortable with that relationship this month, than they were last month. Anyone contemplating an arrangement with Zillow would be well advised to obtain a legal opinion from counsel. It is likely that Zillow will create a “comfort package” that explains why it is now safe to do business with them.

Every day that goes by without the CFPB, or one of the prudential regulators, taking action against Zillow, or those who do business with Zillow, should increases the comfort level for everyone. Slow and cautious makes sense now.

On July 6, 2018 the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (the agencies) issued a statement regarding the immediate impact of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA).

The statement provides information on rules and associated reporting requirements that the agencies jointly administer and that EGRRCPA immediately affected. The agencies will take the described positions in the interim rule until the agencies amend their regulations to incorporate EGRRCPA’s changes. Certain amendments took effect on the day of EGRRCPA’s enactment, whereas other provisions will take effect at a later date.

Limited information is available on a couple compliance issues:

• Exam Cycle – EGRRCPA increases the total asset threshold for well-capitalized insured depository institutions to be eligible for an 18-month examination cycle from $1 billion to $3 billion, making an 18-month examination cycle available to a larger number of “1-rated” institutions, and authorizes the agencies to make corresponding changes for “2-rated” institutions. The agencies intend to engage in rulemaking to implement these provisions.
• Appraisals in Rural Areas – EGRRCPA provides an exemption to the appraisal requirements for certain transactions with values of less than $400,000 involving real property or an interest in real property that is located in a rural area, as specified in section 103 of EGRRCPA. This exemption was effective upon EGRRCPA’s enactment. The agencies are reviewing the statutory provisions to determine whether further action is necessary.

The interagency statement is available at http://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20180706a1.pdf.

For more information about EGRRCPA refer to our recent blog articles:

• https://www.jackscomplianceresource.com/status-of-the-egrrcpa-hmda-amendments/
• https://www.jackscomplianceresource.com/restoration-of-ptafa/
• https://www.jackscomplianceresource.com/egrrcpa-appraisal-relief/
• https://www.jackscomplianceresource.com/regulatory-relief-on-the-way/

A recording of a detailed presentation on EGRRCPA is available at: https://www.jackscomplianceresource.com/product/the-economic-growth-regulatory-relief-and-consumer-protection-act-immediate-compliance-concerns-webinar-recording/

On July 5, 2018 both the Office of the Comptroller of the Currency (OCC Bulletin 2018-19) and the Consumer Financial Protection Bureau issued statements regarding the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) amendments to the Home Mortgage Disclosure Act (HMDA).

The President signed the EGRRCPA on May 24, 2018. Section 104 of the law amends HMDA. The EGRRCPA provides exemptions from certain HMDA requirements for insured depository institutions, with satisfactory or outstanding Community Reinvestment Act ratings, and for insured credit unions. The partial exemptions are generally available:

• For closed-end mortgage loans if the institution originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years.
• For open-end lines of credit if the institution originated fewer than 500 open-end lines of credit in each of the two preceding calendar years.

The partial exemption eliminates the requirement to collect, record, and report some, but not all, of the data points specified in current Regulation C. The data points from Sections 304(b)(5) and (6) are eliminated for this select group of financial institutions.

For all institutions filing HMDA data collected in 2018, the Act will not affect the format of the LARs:

• LARs will be formatted according to the previously-released 2018 Filing Instructions Guide for HMDA Data Collected in 2018 (2018 FIG).
• If an institution does not report information for a certain data field due to the Act’s partial exemptions, the institution will enter an exemption code for the field specified in a revised 2018 FIG.
• All LARs will be submitted to the same HMDA Platform. A beta version of the HMDA Platform for submission of data collected in 2018 will be available later this year for filers to test.

At some unspecified date, later this summer, the  CFPB expects to release the revised 2018 FIG and to provide further guidance on the applicability of the Act to HMDA data collected in 2018.

For more about the EGRRCPA read: https://www.jackscomplianceresource.com/regulatory-relief-on-the-way/; or purchase a two-hour webinar on the topic at:  https://www.jackscomplianceresource.com/product/the-economic-growth-regulatory-relief-and-consumer-protection-act-immediate-compliance-concerns-webinar-recording/

The OCC Bulletin is available at: https://www.occ.gov/news-issuances/bulletins/2018/bulletin-2018-19.html

The CFPB statement is available at:  https://www.consumerfinance.gov/about-us/newsroom/bureau-consumer-financial-protection-issues-statement-implementation-economic-growth-regulatory-relief-and-consumer-protection-act-amendments-home-mortgage-disclosure-act/

Before you read this post, if you haven’t already, please take a few minutes and read my updates from Day 1 and Day 2 of my first ABA RCC.  If you’ve picked up anything from the first two recaps that I’ve written it is likely that I am not a morning person, I hate the sound of forks scraping against plates and you know my face, but I probably don’t know your face.

Now that you are all up to speed, I started my final day at the RCC as you guessed it…EARLY!  I attended a Power Hour session sponsored by RSM called “If You Paint By Numbers, What Does Your HMDA Data Reveal?”.  It was moderated by Rod Farling and featured speakers Tisha Stelken, David Dowdney and Julia De France.  There have been a lot of questions about the new data and EGRRCPA in the HMDA sessions that I have attended this week.  As I mentioned yesterday, the consensus seems to be, “We don’t know”, “Everyone is in a holding pattern”, and “Don’t change anything right now!”.  Please make sure that you are able to justify your data.  They weren’t sure which data will be made public, but it seems they are giving you just enough rope to potentially hang yourself.

Now, we head back to the humongous ballroom for General Session for a presentation on AI and Compliance with Jo Ann Barefoot of Barefoot Innovation Group.  JoAnn told a story about a TechSprint (also known as a hackathon, but that word is a little scary for banks and government agencies) that the Financial Conduct Authority hosted last year.  At this TechSprint, a group of coding professionals were able to take a regulatory handbook and convert it to a programming language that machines could understand.  From there, the computer was able to pull needed information directly from the institution in 12 seconds.  This is just one example of the places that FinTech may be heading.  If you’re familiar with Moore’s Law, which states that computing power doubles each year, computing power has actually grown by 1 billion times.  Yes, that is with a “b” and that is over the last 50 years.  Where will we be in a decade?  Once Jo Ann wrapped up her presentation, she brought on Yvette Hollingsworth Clark the Executive VP and Regulatory Innovation Officer at Wells Fargo for a discussion about RegTech.  There is a thought in the industry that RegTech will help the big banks shoot ahead of community banks, but Yvette believes that is not the case.  She stated that the sheer amount and increased complexity of data held by big banks will force them to roll out in stages.  This leaves an opportunity for smaller community banks to move faster.  However, while that seems to be wonderful to hear in theory, my question is, will community banks have the resources to implement future RegTech before big banks move further ahead?

Following our General Session, it was time for a “coffee break” in the Marketplace.  I made a quick stroll through the booths for what I was sure would be my final time.  It was pretty uneventful.  I snagged a pastry on my way out just to hold me over until lunch.

My next session was “Creating a Compliance Digital Marketing Program” presented by Brian Jensen, Katherine Licup, Maureen Carollo and Renee Huffaker.  This session spent a lot of time spent talking about compliance pitfalls in your company’s marketing programs, but what I found the most interesting was a type of marketing that I was not even aware of.  I know a lot of people are “cutting the cord” when it comes to their television viewing habits, but many of you still have cable or satellite.  Do you have a set top box provided to those companies?  Did you know that they can use your demographic information AND your viewing habits stored on that box to push specific commercials directly to your screen while you are watching television?  I didn’t.  Obviously, you want to watch for UDAAP and privacy as they will always be subject to scrutiny.  A big issue facing many compliance professional in regards to their advertising program is demographic targeting.  Demographic targeting is a fairly essential piece of marketing, but you need to make sure that you aren’t excluding groups of individuals at the same time.  If your online marketing program is targeted at individuals under the age of 55, you need to make sure you’re reaching the 55+ demographic in some other way.  The strength of your CMS needs to move concurrently with the depth of your digital marketing program.

Lunch time!  I made my way to the Marketplace for the absolute final time and got into line for the buffet style lunch.  I’ll let you take another peak behind my curtain.  I’m a picky eater (just ask my wife) and these types of lunches rarely work out for me.  I found the couple of items that I felt like I could handle, found a seat and quickly polished them off.  Lunch was quick, and I had a lot of time to kill, so I made the short walk down to Broadway just so I could see the Honky Tonks before I left the city.  Everyone had always told me, “There are musicians everywhere on Broadway”, but I figured maybe a couple each block.  Well, let me just tell you something, there are literally musicians EVERYWHERE on Broadway.  You couldn’t walk by an establishment without seeing someone playing music.  It was a pretty cool atmosphere.

When I returned from lunch and my little exploration of Broadway, I attended the “BSA/AML/CFT Regulatory Hot Topics” session delivered by Robert Rowe III, Lauren Kohr and Dan Stipano.  They talked about a range of topics from the new CDD requirements, filing SARs, cannabis and sports betting.  In the panel’s experience so far, the examiners really do want to work WITH you on these new CDD requirements.  Also, they think it is a good idea to establish a relationship with your local SAR review team.  One final note on this session…told me to tell you that Risk Assessment is the building block of your BSA compliance system.

Well, that’s the end of my day and the end of my first conference!  Yes, I realize that there is another day, but I had prior requirements that precluded me from attending.  Yes, I do realize that there was another session today after the last one that I attended.  Who wants to leave Nashville at rush hour?  Please don’t tell my boss that I skipped out early.  Let’s just keep this between us!

Overall, I thoroughly enjoyed my first ABA Regulatory Compliance Conference, but I’m exhausted!  I met so many wonderful people and learned more than I will likely be able to remember.  I wanted to accomplish four things when I set out writing this series of blog posts;

1. Be informative for those of you that could not attend;
2. Show those who have never attended what the conference is really like;
3. Help those of you that have attended for many years remember how you felt at your first conference; and
4. Be entertaining!

Did I accomplish all of those things?  I certainly hope so!  Thanks for virtually walking along with me through my first conference.

Brent Vincent

Director of Operations

Compliance Resource, LLC

If you will recall from my recap of Day 1, I’m not typically an early riser.  My day started as early as the conference would allow me with a Power Hour session provided by Treliant.  The speakers for “Seven Steps to Avoid Redlining” were Carl Pry and Susanna Tisa.  This session had a lovely continental breakfast provided, and lots of really informative discussion about…you guessed it, avoiding redlining!  I think my favorite takeaway from this session was that you don’t want your mapping to look like a pastry.  If your mapping area looks like a croissant or doughnut, you are probably at risk for a redlining violation of some sort.

Once my breakfast had been consumed and I had learned the broad points of how to do the right thing, I headed to the general session.  The speaker in the gigantic ballroom was ABA President Rob Nichols.  Rob spent some time telling us about the conference and the way the industry is heading as a whole.  He also gave us a demonstration involving their new website www.grow.aba.com.  This website is dedicated to showing how banks all over the country impact their state and the American economic system.  As Rob said, “United States banks are the cardiovascular system for the most dynamic economic system in the world.”  He also talked about the Economic Growth, Regulatory Relief and Consumer Protection Act as just about everyone here has.  He summed up what the consensus has been…we don’t really know quite yet what it means, but now is not a time to relax.   He wrapped up with this quote, “Regulatory changes will take time and compliance is more important now.  Double down on compliance!”

What do 2,000+ bankers do when they finish listening to the ABA President?  I thought you’d never ask.  The answer is coffee.  A lot of coffee.  Day 2 seemed to have a lot more “down time” than day 1, and this is an example of that.  The Marketplace is an interesting animal.  If you’ve ever been to this sort of event, in any industry, you know exactly what I am talking about.  There are rows of booths with vendors hoping that the passerby will show some sort of interest.  Strategically placed swag, flashy videos, and prizes are just a few examples of strategies they will employ in hopes of getting your contact information.  It’s not an easy job and I feel for them as I walk past.  However, that’s not the only purpose for the Marketplace.  Hundreds of attendees can be found inside exchanging stories and business cards with their colleagues.  As a first time attendee, this puts me in a little bit of an interesting spot because I have few contacts here.  I did see a lot of our Compliance Masters Group members, but I will talk more about them in a bit!

Following the “coffee break”, I made my way to my first break out session.  “Troubleshooting Your CDD Program: Where Are We?” was presented by Robert Rowe III, Megan Hodge and Daniel Stipano.  This session certainly moved at a brisk pace and it was clear that all three speakers knew the subject matter very well.  They spent a significant amount of time talking about the new Beneficial Ownership Rules as they apply to rollovers and renewals.  They spoke about the 90-day limited exceptive relief and the need to have policies and procedures in place in the event that a customer refuses to provide beneficial ownership on renewal of a CD.  Obviously, they spent time speaking on trigger events which led to possibly the line of the sessions when Daniel Stipano said, “Death is the ultimate triggering event!”.  The parting thoughts were to not lose sight of the bigger picture and know your customer.

That brings us all the way up to lunch which was a little bit different than yesterday’s box lunch.  We had two hours blocked in the gigantic ballroom for a seated luncheon with Jennifer Tescher, President and CEO of the Center for Financial Services Innovation.  First, let me talk about the lunch setting.  The portions, for anyone that has every played Oregon Trail, could only be described as meager.  They have to serve 2,000 people in the course of an hour before the speaker begins, so I can understand I suppose.  I was a bigger fan of the sandwich on Day 1.  Also, as a person with a slight bit of misophonia, the sound of thousands of people using forks and knives against plates was a bit overwhelming.  If you aren’t familiar with misophonia it is defined as “a strong reaction to specific sounds” and it is REAL!  Jennifer Tescher gave a wonderful presentation about the state of financial health for individuals all over our country.  You’re not just in compliance business, you’re not just in the banking business, you’re in the financial health business.

The luncheon was followed by some nice chess pie in the Marketplace and the same hobnobbing and networking that I discussed prior.  Then, I made my way straight towards my next session on Fair Lending Hot Topics.  The session was moderated by Cara James and was a Q&A style presentation by Anand Raman, Andrea Mitchell, Melanie Brody and Paul Hancock.  These four attorneys waded through a variety of hot topics in the Fair Lending area.  Redlining was a frequent topic visited throughout the session and was part of the conversation while speaking on the Bureau moving away from auto loans, the DOJ using publicly available information and Fintech.  They also mentioned that acting director Mulvaney suggests that the Bureau will reopen Reg B to address Disparate Impact Theory of Liability in respect to Inclusive Communities.  The overriding theme for this topic was, “Try to do the right thing”.

The final session of the day for me was a HMDA flash session presented by Robert Rowe III.  Flash sessions are 45 minutes and it was over before I realized it.  Basically, don’t get too excited about these HMDA exemptions for smaller institutions until we know what they actually mean.  Do not change anything.  Are you thinking about selling these loans at a later date?  Well, you may run into an issue if you haven’t been collecting all the data.  What happens if you are selling to an institution who is required to collect ALL of the data?

I thought when I started to put together this blog post that it wouldn’t be quite as long as yesterday’s.  I guess I was wrong about that, but I cannot wrap this up without talking about the low key cocktail hour that we hosted for our Compliance Masters Group members.  This was by far my favorite part of the conference!  I talk to these people over the Internet at least three times a month, and it was so wonderful to be able to put faces with names.  I’ve spent my week trying to figure out who is saying, “Hi, Brent!”.  It is so odd to be in a scenario where people know your face, but you only know them by name…maybe by voice.  I don’t think I could have had more fun spending time with somewhere between 15-20 of our members at Barlines in the Omni Hotel.  I loved hearing all of the stories that they shared as friends who had attended these conferences together for years.  As I look forward to my final day of my first ABA RCC, this was added another level of excitement for future attendance that I hope to be blessed with in the coming years.  There are a lot of good people here, and I feel lucky to have some of the best of those people right in our own Compliance Masters Group.  I’m heading to bed as I prepare to, once again, wake up much earlier than I would like to.

On June 21 the Federal Reserve Board published a Consumer Affairs Letter entitled Restoration of the Protecting Tenants at Foreclosure Act (CA-18-4), which is a reminder that the Protecting Tenants at Foreclosure Act (PTAFA), which had expired on December 31, 2014, has been restored by the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA).

Section 304 of EGRRCPA, which was signed into law on May 24, 2018, restores PTAFA effective on June 23, 2018. Although the reminder was published by the Federal Reserve Board, let us remind you that the reinstatement of PTAFA impacts all banks, not just Fed members.

The interagency examination procedures for PTAFA, previously used by the agencies, are being restored as well.

For our recent article on EGRRCPA go to: https://www.jackscomplianceresource.com/regulatory-relief-on-the-way/

A copy of the Consumer Affairs Letter is available at: https://www.federalreserve.gov/supervisionreg/caletters/caltr1804.pdf

For more information regarding the EGRRCPA visit:  https://www.jackscomplianceresource.com/event-registration/?ee=180

I have the distinct privilege of representing Compliance Resource at this year’s ABA Regulatory Compliance Conference (RCC) in Nashville, TN.  I thought it may be nice to provide you a series of blog articles written from the perspective of a first time attendee.  I hope that you enjoy sharing in my simultaneous excitement and misery!

I left Louisville, Ky at 7:00 AM Sunday morning.  That is earlier than I am typically up and moving, but judging by the schedule I have planned for the week, it will be more of the norm!  Once I arrived in Nashville, I checked my bags at the front desk of my hotel and ran across the street to the conference center.  I knew it was going to be massive, but I was not prepared for the size of the venue or the massive crowd!  I am but one of a record setting crowd that has been reported to be over 2,000 bankers and consultants.  I took a little bit of time to get the lay of the land and I’m thankful to report that there is definitely an adequate amount of signage and arrows all over the Music City Center.  Now, with my badge in hand, I was ready for my first session.

What better place to dig in than HMDA, right?!  My first session was “New HMDA Data Implementation and Lessons Learned” with presenters Rick Freer, Kitty Ryan and David Dickinson.  This session was an hour and thirty minutes, but as all of you know, it probably would have been better suited as a full day (full week?) program.  They packed a ton of information into this session and they moved quickly.  As someone without a background in HMDA, my head was spinning with exemptions and exemptions for exemptions.  I tried to pull at least one quote from every session that I’d like to share with all of you, and my favorite from this session belonged to David Dickinson.  If you don’t have the time to do it right, you will find the time to do it TWICE!”

With thoughts of HMDA swirling through my head, I made my way to a session about Proactive Management Systems.  “If Everything is a Priority – Then Nothing is a Priority” was presented by Gary Pacos, Samuel Burruano and Andy Dell.  This session started off hot with a couple of clips of Michael Scott from the Office and was filled with a ton of examples of way that you can get out in front of issues that may arise in the Compliance department.  One takeaway from this session was that as Compliance professionals you shouldn’t get used to saying “no”.  Dig in, find out why they are presenting something to you and attempt to find a way in which you may be able to say “yes”.   You do not want to become the “No Department”.

LUNCH TIME!  Lunch was a welcomed break from filling my head with all of this knowledge.  They provided box lunches for everyone and it all ran smoothly.  There wasn’t much of a line and everyone was able to eat and make it to their next sessions in time.  Two hours went by much more quickly than I would have thought it would!

Following lunch, I made my way to my next session which focused on ADA accessibility.  “Website Rehab: Disclosures and Accessibility in the Digital Age” was presented by Derek Featherstone, Charles LeFevre Jr. and Sharri Logsdon.  The title of this program was a little misleading as it dealt with much more than just your website.  They spoke on everything from ways to make your website more inclusive all the way to making your branch more accessible to everyone regardless of disability.  Sharri Logsdon even spent some time talking about how her bank had worked with the autism society in her area to make their branches an autism friendly environment.  There were some items in this session that changed the way I think about accessibility.  We all want accessibility features.  You want to be able to watch videos with closed captions on Facebook, or we want our phone to vibrate for a text instead of making a loud noise in one of these sessions.  These are things that those of us without a disability WANT, but they are very similar to things that someone with a disability NEEDS.  When you develop to make things accessible for everyone, it makes for a better experience for everyone…not just those who NEED it.  Accessibility is the outcome of the inclusive design process.

My final session of the day was the Three Lines of Defense roundtable discussion led by Ryan Rasske and featuring Michael Little, Richard Harvey Jr. and Stacey Guardino.  The ballroom that they held this in was absolutely massive, but I suppose it needs to be with over 2,000 attendees.  This was filled with a lot of really great discussion about breaking the walls down between the three lines.  In compliance, you want to be invited to the party, but you may not be getting invited because they are afraid you’ll shut it down.  You need to find a way to be at the party early enough so that you can shape it in a way that they will want you at the next party.  They spoke a little bit on the “regulatory relief” on the way.  When asked what his elevator pitch to his CEO asking him to cut resources would be, Richard responded with this, “Our last few exams have gone well because of the things that we have put in place.  Now is NOT the time to back compliance down.”  The session wrapped up with Patti Blenden receiving the ABA Distinguished Service Award.  Patti gave a very entertaining, funny and enlightening speech to accept her award.  As someone who has never seen Patti speak, it is clear why she is regarded as such a great speaker.

I realize that much like my day, this post has become much longer than I expected it to but we are almost finished.  I wrapped up my day at the marketplace by perusing the booths and handing out business cards for a bit.  I made new connections, connected with people I already knew, and grabbed a couple of freebie items from booths.  Maybe I’ll win one of those Amazon Echos from the business card fishbowl.  All I know right now is that I am tired, my head is spinning and I’m ready to crash.  It was a great first day at my first RCC.

Brent Vincent

Director of Operations

Compliance Resource, LLC

The ABA Regulatory Compliance Conference (RCC) got under way this weekend. A record-setting 2,035 compliance geeks are in attendance at the Music City Center in Nashville, TN through Wednesday. The RCC is always a great opportunity to make new friends and to reconnect with old ones.

As is typical there are more training sessions that any one person can possibly cover. Attendees have to pick their shots. Interesting topic titles this year include:

• My Lines Are Blurring: 1^st and 2^nd Line Roles and Responsibilities
• If Everything is a Priority – Then Nothing is a Priority
• Banking Cannabis
• Keep Your Eyes on the Ball: Don’t Strikeout on Your Next Compliance Examination

The days are long. The large crowd begins each day full of enthusiasm and excitement, but as the day unfolds and they cram more information into their heads than their brains can hold exhaustion sets in. But night after night they rally for dinner, a few adult beverages and some great live music in the local honky-tonks.

The ABA is doing a better job of crowd control. After years of pouring thousands of attendees in to a venue and overwhelming the support system this year’s event is going smoothly. By allowing more time for lunch and providing a box lunch option on Sunday everyone was able to actually make the post lunch sessions.

The RCC continues to be an amazing event.