Compliance Huddle FEBRUARY 2017

Recent Exams Does anyone currently have examiners on-site? Is there still a continuing increase in request information? What is the focus of the on-site? Has anyone just been through an exam or recently received their ROE? Has examiner “tone” changed from the last on-site? Are the reports giving credit where credit is due, or if there were concerns, are the reports written in such a way that the regulators are seemingly sympathetic or more demanding? What are some of the areas of focus? Please click the “raise hand” button by your name if you would like to speak and we will unmute you. Please be prepared for all background noise/speaking to be heard as soon as you raise your hand.

HMDA Phases In First Phase: 1/1/17 Primarily affects low volume institutions, not much change for larger institutions Second Phase: 1/1/18 Effective date for most provisions New data collection fields required Third Phase: 1/1/19 Enforcement changes and some additional reporting amendments Last Phase: 1/1/20 Quarterly reporting Please click the “raise hand” button by your name if you would like to speak and we will unmute you. Please be prepared for all background noise/speaking to be heard as soon as you raise your hand.

HMDA How is your bank preparing for the new data submissions? Do you have the resources to handle the expanded reporting requirements? Are you working with software providers? Any indication if providers will be ready? Budget: how much is this going to cost? Any other concerns?

Beneficial Ownership Reliance on 3rd Party CIP Are others doing this? Any regulatory criticism?

New Compliance Rating System Has anyone had an exam under the new rating system?

Regulatory Freeze How will this impact your bank? http://buckleysandler.com/uploads/1551/doc/BuckleySandler_Special_Alert_- _Trump_Administration_Initiates_Regulatory_Freeze.pdf How will this impact your bank? What rules are you waiting on? Does this help or hurt?

Anything Else on Your Mind… Please click the “raise hand” button by your name if you would like to speak and we will unmute you. Please be prepared for all background noise/speaking to be heard as soon as you raise your hand.

Questions? Thank you for your participation and input into the conversation! If you have any additional questions, contact Compliance Alliance at hotline@compliancealliance.com or 888-353-3933. Please click the “raise hand” button by your name if you would like to speak and we will unmute you. Please be prepared for all background noise/speaking to be heard as soon as you raise your hand.