1. 4 Webinars, 4 Perspectives Implications of Dodd-Frank Act PART 1: ANTI-STEERING & LOAN OFFICER COMPENSATION PART 2: IMPACT TO HEDGING PART 3: IMPLICATIONS FOR DOCUMENT COMPLIANCE December 16 PART 4: IMPACT TO YOUR LOS December 21

2. Ask Questions 2

3. Implications of Dodd-Frank Act Part 3: Implications for Document Compliance December 16, 2010

4. 4 Tom Walter recently returned to Wolters Kluwer Financial Services as a Compliance Consultant in Professional Services. Tom’s current responsibilities include developing new consulting services, supporting consulting engagements, and providing specialized research and fulfillment services. Most recent activities have centered on multistate program development and compliance education focusing on Truth-in-Lending and the Dodd Frank financial reform law. In addition to his experience at Wolters Kluwer Financial Services, Tom has years of banking and bank regulatory experience, including many years as a field examiner, compliance officer and compliance vice president. Tom earned his Juris Doctor degree from William Mitchell College of Law. Thomas Walter Wolters Kluwer Financial Services Compliance Consultant, Professional Services 6815 Sauk View Drive, Saint Cloud, MN, 56303 320.240.5533 tel 320.240.4540 fax Tom.Walter@wolterskluwer.com

5. Agenda Dodd-Frank Introduction Bureau of Consumer Financial Protection Regulatory review Combined RESPA TIL disclosures Changes in Preemption Regulatory Improvements Conforming Amendments Questions and Answers 5

6. Dodd-Frank: A Brief Introduction Passed July 21, 2010 2,300+ pages 16 titles Eliminates OTS Most rulemaking goes to new Bureau 6

7. Establishment of Bureau Consumer Financial Product or Service Covered Person Ombudsman Enumerated Consumer Laws 7 Bureau of Consumer Financial Protection

8. BCFP Enumerated Consumer Laws 8 Alternative Mortgage Transactions Parity Act (AMTPA) Consumer Leasing Electronic Funds Transfer Act Equal Credit Opportunity Act Fair Credit Billing Act Fair Credit Reporting Act (With exceptions) Home Owners Protection Act (HOPA) Fair Debt Collection Practices Act Federal Deposit Insurance Act Gramm-Leach-Bliley Home Mortgage Disclosure Act Home Ownership and Equity Protection Act (HOEPA) Real Estate Settlement Procedures Act SAFE Mortgage Licensing Act Truth In Lending Act Truth In Savings Act Omnibus Act of 2009 Interstate Land Sales Full Disclosure Act

9. General Powers of the Bureau Purpose To implement and, where applicable, enforce federal consumer financial law consistently for the purpose of ensuring that all consumers have access to markets for consumer financial products and services, and that markets for consumer financial products and services are fair, transparent and competitive 9

10. Bureau: Transfer of Functions and Personnel 10 Designation of Transfer Date July 21, 2011 Status of Rules Proposed rules will transfer to the bureau Rules not yet effective will become rules of the bureau Mortgage reform rules must be issued in final form within 18 months after transfer date, to be effective within 12 months after that

11. General Powers of the Bureau Rulemaking Authority General authority Standards FSOC Review of Bureau Regulations Power Process 11

12. General Powers of the Bureau 12 Non-Depository Institutions Coordinate with Federal Trade Commission Large Depository Institutions Institutions over $10 billion and any of their affiliates Other Institutions Exclusions Restriction on Mandatory Pre-Dispute Arbitration

13. Specific Bureau Authorities 13 Unfair Deceptive or Abusive Acts or Practices Terms defined Disclosures Standards and Safe Harbor Mortgage booklet Combined TIL/RESPA

14. Sample Combined Form – Page 1 14

15. Sample Combined Form – Page 2 15

16. Sample Combined Form – Page 3 16

17. Sample Combined Form – Page 4 17

18. Changes in Preemption: Preservation of State Law 18 Preemption standards Codifies Barnett standard Preemption if state law substantially hinders national bank or thrift’s exercise of its powers State laws that discriminate against nationally-chartered institutions are preempted No preemption coverage for subsidiaries Enforcement by State Attorney General

19. Regulatory Improvements 19 Small Business Data Collection Information gathering Record of responses Customer’s right to refuse No access to data by underwriters Itemization of information required Personally identifiable information not included Data to be submitted to the bureau Definition of terms

20. Regulatory Improvements 20 Use of Consumer Reports Institutions will have to provide the consumers’ credit score on adverse action notices and risk-based pricing notices based in whole or in part on a consumer report They will also have to provide the information now given on credit score disclosures—the range of scores, key factors, date of the score and person creating the score

21. Regulatory Improvements 21 Reverse Mortgages Study to be done within one year of transfer date on need for conditions or limitations on reverse mortgages Regulations to be issued, if found to be necessary Regulations would target unfair, deceptive or abusive practices

22. Conforming Amendments 22 Expedited Funds Availability Amendments The amount required for next day availability has increased from $100 to $200 Funds Availability dollar amounts must be adjusted for inflation every five years Fair Credit Reporting Act Amendments New model forms must be issued by the bureau for providing a notice regarding negative information about the consumer Regulations may be issued restricting the inappropriate use of medical information

23. Conforming Amendments 23 Points and fees payable at origination The difference between the APR and a benchmark rate Pre-payment penalty information The value of real property pledged as collateral The term of any introductory period before an interest rate change Whether payments other than fully amortizing payments may be made The channel through which the application was made Unique identifiers for the originator under the SAFE Act A universal loan identifier, a property parcel number A credit score Any other information that the bureau may require HMDA Additional Information

24. Conforming Amendments 24 Omnibus Amendments Regulations required regarding unfair or deceptive practices regarding mortgage loans, including loan modification and foreclosure rescue services

25. Conforming Amendments 25 RESPA Amendments Requires a single, integrated disclosure for mortgage loan transactions using understandable language to aid consumer understanding Booklets to help borrowers understand real estate settlement services

26. Conforming Amendments 26 Truth in Lending Amendments Gives authority to prescribe rules to prevent circumvention or evasion of TILA, and to facilitate compliance by motor vehicle dealers Truth in Lending Inflation Increases the TILA dollar amount for exempting credit transactions or leases from $25,000 to $50,000 Provides for future indexing for inflation

27. How Can Wolters Kluwer Financial Services Assist You? 27 Order our manual Dodd-Frank Wall Street Reform and Consumer Protection Act: Law, Explanation and Analysis for comprehensive coverage of this historic legislation http://onlinestore.cch.com/default.asp?ProductID=7342 Check out and subscribe to ComplianceHeadquarters™ for the timely and accurate compliance information financial institutions need Compliance Calendar - Highlighting important upcoming regulatory events Research Library - Links to the basic banking compliance laws and regulations Compliance News - Accurate and timely information Compliance101 - Quick introductions to a variety of topics Plus more from the financial industry experts at Wolters Kluwer Financial Services Visit us at www.WoltersKluwerFS.comwww.WoltersKluwerFS.com Contact your Wolters Kluwer Financial Services Inside Sales Representative for more information at 1.800.397.2341

28. Question & Answer 28

29. Implications of Dodd-Frank Act Part 3: Implications for Document Compliance December 16, 2010

30. 4 Webinars, 4 Perspectives Implications of Dodd-Frank Act PART 1: ANTI-STEERING & LOAN OFFICER COMPENSATION PART 2: IMPACT TO HEDGING PART 3: IMPLICATIONS FOR DOCUMENT COMPLIANCE December 16 PART 4: IMPACT TO YOUR LOS December 21