thursday, september 24, 2015 1:30 - 5:00 pm
TRANSCRIPT
Thursday, September 24, 2015 1:30 - 5:00 pm
Meeting Location : The University Club of Tampa - 201 N. Franklin Street, 38th Floor, Tampa, FL 33602
Parking Instructions : Parking is available in the Fort Brooke Garage at the NW corner of Florida and Whiting. The 3rd floor of the garage has a covered walk- over to the building.
Arrival : Please arrive 5-10 minutes prior to your session’s start time to allow yourself plenty of time to check in and get settled.
Dress : Business Casual. Please also consider bringing a sweater or jacket for your comfort.
CPE: 3.75 hours crcm/3 hours cams (CFE eligible)
September 24, 2015 The University Club of Tampa
Welcome from Saltmarsh & Program Overview Kristen J. Stogniew, Esq., CFE, Saltmarsh, Cleaveland & Gund
1:30 AML, Fraud and BSA from the Perspective of Law Enforcement Professionals Working with Financial Institutions Anita Cream, US Department of Justice Kimberly Lappin, IRS Criminal Investigations Division Special Agent Richard Dunn, Department of Homeland Security
2:30 Break
3:30 Break
3:45 Compliance Officer Panel Sheila Roberts, Crews Banking Corporation Sarah Oliver, Bank of North Carolina Larry Goldberg, Professional Bank
4:45 Regulatory Update, including: Fair Lending, TRID, ACH and BSA Regulatory Focus Kristen J. Stogniew, Esq., CFE, Saltmarsh, Cleaveland & Gund
Keep the Conversation Going! Use #SaltmarshBankTalk before, during and after each session to share your questions,
feedback and event photos!
Richard M. Dunn | U.S. Department of Homeland Security [email protected]
Supervisory Special Agent (SSA) Richard Dunn has almost 15 years of federal experience as a Criminal Investigator/Special Agent. He commenced federal service in 2001 with the U.S. Department of the Treasury, U.S. Customs Service in Queens, New York, specifically JFK International Airport where he primarily worked narcotics and money laundering investigations until January 2008 when he transferred to Tampa, Florida.
While at JFK, Rich was assigned to the JFK Narcotics Smuggling Unit (JNSU) where he was intimately involved in numerous complex investigations that resulted in the identification, disruption, and dismantling of transnational criminal organizations involved in money laundering, narcotics trafficking, weapons trafficking, document fraud, and human smuggling.
In January, 2008, Rich transferred to the HSI Tampa Office where he worked in the Narcotics Smuggling Group until 2010 when he was reassigned to the HSI Tampa Financial Group. During his tenure at the HSI Tampa Office, Rich continued to work complex investigations, which focused on and have subsequently led to the identification, disruption and dismantling of transnational criminal organizations.
In 2014, Rich was promoted and is currently the supervisor in charge of the Financial Investigations Group and the Asset Identification and Removal Group (AIRG).
Kimberly A. Lappin | IRS, Criminal Investigation, Tampa Field Office [email protected]
Kimberly Lappin is the Special Agent in Charge of the IRS, Criminal Investigation, Tampa Field Office. She began her Internal Revenue Service career in 1988 as a Special Agent in Albany, New York. In 1998, Ms. Lappin served as an Instructor at the Federal Law Enforcement Training Center (FLETC) in Glynco, Georgia and was responsible for course development and instruction to new special agents in both the IRS Special Agent Basic Training and FLETC Criminal Investigation Training Programs.
Since 2001, she has held various increasingly responsible management positions including Supervisory Special Agent in Orlando and Senior Program Analyst on the Review & Program Evaluation staff in Washington DC.
In 2011, Ms. Lappin was selected as the Director, of CI’s Office of International Field Operations – EAST. In that position she provided operational oversight and leadership to IRS posts in Hong Kong, London, Frankfurt and Sydney and Europol. Specifically, she oversaw efforts to combat international criminal tax fraud and money laundering for the IRS Posts.
Ms. Lappin has also served as Acting Executive Director and Deputy Director of International Operations.
2015 Financial Institution Compliance Funnel | Saltmarsh, Cleaveland & Gund
Financial Institution Compliance Funnel Speaker Biographies
ShaDonte Butler | Federal Home Loan Bank of Atlanta (FHLB) [email protected]
As Business Development Manager, ShaDonte focuses on cultivating and expanding the Bank’s customer relationships and driving new business to the Bank through its Community Investment Products. Prior to joining the Bank in 2009, she worked in a variety of roles within Fannie Mae’s Single Family Mortgage Division. Her most recent position was Sales Support Manager in which she developed operational efficiencies to increase new customer acquisition and developed effective sales techniques and procedures to successfully position Fannie Mae’s product and technology offerings.
ShaDonte earned a Bachelor of Science degree in finance and economics (summa cum laude) from Fisk University in Nashville, TN, a Master of Business Administration specializing in Finance from Clark Atlanta University and a Master of Science in Building Construction/Residential Development from Georgia Tech.
2015 Financial Institution Compliance Funnel | Saltmarsh, Cleaveland & Gund
Jacquie Moore | Bank of Tampa [email protected]
Jacquie Moore is Senior Vice President, Chief Risk and Compliance Officer of The Bank of Tampa. Jacquie joined the bank in September 2011, with more than 20 years of banking experience.
Prior to joining the bank, Jacquie worked as a Compliance Analyst with the FDIC, performing examinations for state banks in reviewing for compliance with federal regulations. The Bank of Tampa is the only Bank in Florida since 2010 to have received Outstanding CRA ratings (4/2010 as a Large Bank and 7/2013 as an Intermediate Small Institution).
Jacquie holds a degree from Georgia State University and has earned her American Bankers Association (ABA) designation as a Certified Regulatory Compliance Examiner.
Anita M. Cream | U.S. Department of Justice [email protected]
Assistant United States Attorney Anita M. Cream has been the Chief of the Asset Recovery and Victim’s Rights Division (ARVRD) of the United States Attorney’s Office for the Middle District of Florida since 2002. The ARVRD is responsible for handling all civil and criminal asset forfeiture cases for the district, running the Suspicious Activity Report Review Teams in Orlando, Jacksonville, Tampa and Ft. Myers and federal debt collection for the district and coordinating with victims and witnesses in criminal cases.
Prior to becoming the ARVRD Chief, Anita served in the Criminal and Civil Divisions. She has handled bankruptcy, defensive and affirmative civil cases as well as criminal tax, drug, fraud, and money laundering cases.
She graduated from Georgetown University Law Center, cum laude, in 1995. After graduation, she worked as a litigation associate at Akin, Gump, Strauss, Hauer & Feld, LLP, in Washington, DC before joining the U.S. Attorney’s Office.
Financial Institution Compliance Funnel Speaker Biographies
2015 Financial Institution Compliance Funnel | Saltmarsh, Cleaveland & Gund
Kristen J. Stogniew, Esq., CFE | Saltmarsh, Cleaveland & Gund [email protected]
Kristen is a shareholder in the Financial Institutions Advisory Group of Saltmarsh, Cleaveland & Gund. Prior to joining Saltmarsh, she served as executive director of Stogniew & Associates, a consulting firm started in 1980 by her father, Gerry Stogniew, where she oversaw the provision of internal audit, loan review and compliance audit services to community banks and credit unions in Florida, Tennessee and California.
Kristen has been providing legal advice and audit services in regulatory compliance and financial institution operations since 1995. At Saltmarsh, she continues to provide risk management, policy and procedure drafting, compliance audit and monitoring, and related consulting in areas such as: BSA, AML model validation, loan and deposit compliance, marketing and retail delivery, trust, governance, UDAAP and ACH. Kristen also provides one-on-one mentoring and customized training to staff, management and Financial Institution Directorate.
Sheila Roberts, CRCM | Crews Banking Corporation [email protected]
Sheila Roberts is the Chief Compliance Officer for Crews Banking Corporation, which includes Wauchula State Bank, Wauchula, $604,123 in assets; First State Bank or Arcadia, Arcadia, $138,550 in assets; Charlotte State Bank & Trust, Port Charlotte, $304,505 in assets; and Englewood Bank & Trust, Englewood, $228,408 in assets.
She is the Privacy Officer for First State Bank of Arcadia and Charlotte State Bank & Trust and the CRA Officer for First State Bank of Arcadia, Charlotte State Bank and Trust and Englewood Bank & Trust. Sheila has served as BSA Officer for First State Bank of Arcadia, Charlotte State Bank & Trust and Englewood Bank & Trust.
Larry Goldberg | Professional Bank [email protected]
Larry Goldberg is a compliance executive with more than 30 years of government and bank experience. He is a former examiner with the Federal Reserve Bank of Atlanta and has served as Chief Compliance Officer and Risk Management Director for several Miami-based financial institutions having both domestic and international operations. Most recently he was Chief Compliance/Risk Management Officer for Coconut Grove Bank.
Larry attended the University of Florida where he earned his Bachelor of Science degree in Business Administration. He holds several certifications within the banking industry related to compliance including Certified Regulatory Compliance Manager (CRCM), Certified Anti-Money Laundering Specialist (CAMS), Certified Risk Professional (CRP) and Anti-Money Laundering Specialist (AMLP). Larry is also the current President of the South Florida Compliance Association.
Sarah Oliver, CRCM | Bank of North Carolina [email protected]
Sarah is a career Compliance Officer who began working in consumer compliance over 10 years ago. She has worked for institutions ranging in asset size from $130 million to $15 billion. In addition to assisting with compliance exams performed by the FRB of Atlanta, she has experience working under the direct purview of the CFPB. Sarah currently works as the Compliance Testing Manager for the Bank of North Carolina. She is particularly disciplined in FCRA, Social Media and Credit Card compliance matters and is also a recent graduate of the FBA’s School of Banking, earning academic honors there.
She is passionate about the banking industry and publishes monthly compliance-related posts written in simple language on her LinkedIn blog - https://www.linkedin.com/in/saraholivercrcm
AML, Fraud & bsa from the perspective of law enforcement
professionals working with banks
Anita Cream
9/18/2015
1
ShaDonte Butler, Community Business Development Manager September 24, 2015 Tampa, Florida
Disclaimer
Certain information contained herein has been prepared by FHLBank Atlanta from third-party and market data and using analytical tools it believes to be accurate and reliable. No warranty, expressed or implied, however, is made concerning the completeness or accuracy of such information. The analysis and applications contained herein are provided for illustrative purposes only and are based on certain assumptions that FHLBank Atlanta believes to be reasonable. Different assumptions, however, may lead to materially different results. Additionally, past performance and experience with respect to similar financial products may not necessarily be indicative of actual results.
The information, analysis, and applications contained herein should not be relied upon as a substitute for your own business judgment and independent review. You should consult your own regulatory, tax, business, investment, financial, and accounting advisors, and should perform your own suitability analysis, before entering into any transaction or structure described herein. Sophisticated financial products are risky and are not appropriate for all persons. FHLBank Atlanta is not a registered investment advisor and does not advise persons on the advisability of investing in, purchasing, or selling sophisticated financial products or the means by which any such product may be utilized.
Nothing in the information herein should be considered an offer to sell or a solicitation of an offer to buy any securities or derivative products. FHLBank Atlanta is not obligated to update or keep current the information or applications contained herein. FHLBank Atlanta may own or have a position relative to certain securities or other financial instruments discussed in this information or used in this analysis. Neither FHLBank Atlanta nor any of its directors, officers, employees, agents, attorneys, or representatives shall have any liability for any loss or damage arising out of the use of all or any part of this information.
All information is indicative of the time this presentation was written.
2
9/18/2015
2
• Connecting the Dots – Scale and Impact
• CRA Business Development Rental and Ownership Products
• CRA Business Development Services
• How Can We Help You Succeed?
Our Discussion Today
9/18/2015
3
• Lack of capital for small businesses
• Spurring economic development to create permanent jobs with a livable wage
• Lack of capacity and resources for communities and organizations working to meet the needs of constituents
The Challenges
5
• Clearly illustrate how your bank’s CRA philosophy is integrated into the culture
• Commitment from management and the board
• Shared accountability
• Develop Performance Context • Assess community needs • Match bank products and services with
community credit needs • Develop performance and rating goals and
objectives • Track and monitor performance
Develop an Effective Strategic Plan
7
• Framing Performance Context • Description of institution
• Description of assessment area(s)
8
9/18/2015
5
• Develop a community profile for each assessment area (AA) • Bank capacity and business strategy • Operating changes since the prior CRA exam • Geographic footprint • Demographic data • Economic conditions • Competitive environment
* Highlight what you do well!
Performance Context
• Review demographic data
• Contact community partners
• Assess community needs
• Public Entities • Agencies or affiliates of federal, state and local
government • Economic and community development • Small Business Administration • Housing Authorities
• Private Entities • Community Development Financial Institutions (CDFIs) • For profit and nonprofit housing developers • Community Development Credit Unions • Community Housing Development Organizations
(CHDOs) • Minority and Women-Owned Financial Institutions
Assess Opportunities
• Analyze lending practices and loan products
• Analyze retail banking products/services
• Analyze your bank’s position in the market (competition)
• Are there any gaps between community needs and the types of credit and services available at your bank?
9/18/2015
7
Service Opportunities
Multi-Bank loan pools Deposits or grants to CDFIs, CDCs, CDEs, Minority and women- owned financial institutions
Technical assistance to nonprofits, CDFIs and CDCs
Loans to CDFIs or CDCs for housing or small business lending
LIHTC or NMTC projects
Loans for affordable rental housing
Contributions to local CD organizations
Foreclosure prevention counseling
How Can FHLBank Atlanta Help Advance Your CRA Success Story?
9/18/2015
8
Value of Products
• Assist you in achieving your lending and services objectives in your CRA exam
• Borrowers’ incomes must be less than or equal to 80% of AMI
Value of Services
Loan Growth
Value of Services
Products • Homeownership products
drivers in your market area
• Realtors, developers, local government, HFAs, and nonprofits
• Connecting you to the military community
• Marketing assistance
• Structured partnerships
• CRA consultations
17
Structured Partnership Products
Expanding Your Eligible Customer Base New! FHLBank Atlanta AHP Income Limit Methodology and Calculator
18
• Selects the greatest of four calculation methodologies
• Point-and-click Calculator automatically provides the highest income limit
• 548 of 599 counties in the Bank’s district (91%) now have a higher income limit!
Old Methodology Highest of New Methodology % Higher than Old Methodology
$38,150 $46,150 21%
9/18/2015
10
Sellers contribution $0
Closing Costs $2,836
81.6%
99.2%
Business Value: Reduce Loan Risk in Transactions Ownership Example - Transactional Level
19
Sellers Contribution $0
Closing Costs $7,680
91.9%
99.8%
THE PRODUCTS
(LIHTC)
• Reduces project debt service • Which thereby permits a reduction in
project rents to enable affordability
• Use of Funds • Acquisition
THE PRODUCTS
$500,000 AHP Subsidy 55 rental units
Waterfront Rescue Mission – Pensacola, FL $500,000 AHP Subsidy
100 rental units
Acquisition $590,000 $590,000
Soft Costs $1,716,414 $65,000 $106,161 $2,063,862
Other Costs $2,143,311 $547,815 $858,851 $3,014,288
Total Development Budget $13,610,007 $612,815 $1,100,000 $11,897,192
Total Debt – First Mortgage $1,100,000
Member Loan-to-value (LTV/Cost) 8.1%
Member LTV/Cost if AHP converted to Debt
12.6%
DCR 1.36
DCR if AHP converted to Debt (7% for 15 years) 0.71
21
Rental Example: Extend Credit and Reduce Loan Risk
“AHP has the ability to fill funding gaps.” – FHLBank Atlanta Shareholder
THE PRODUCTS
22
• Shareholder sponsored the AHP Competitive application for the direct subsidy • Which could be CRA-eligible Service Opportunity
• Tenants in project are all at 80% or below of area median income • Which would position project as a CRA-eligible activity
THE PRODUCTS
9/18/2015
12
Services
• Connections to Business Drivers: FHLBank Atlanta has a database of more than 4,000 developers, realtors, contractors, nonprofits, etc. that can be shared with shareholders
• Can be sorted by local market
• Marketing: FHLBank Atlanta provides templates homeownership product marketing
• Templates available at www.fhlbatl.com
• Direct assistance with shareholders
• Education and Outreach: FHLBank Atlanta partners with shareholders to lead webinars, host business development events, and conduct other outreach to grow their business
THE SERVICES
23
Success Stories: Leveraging AHP to Grow Business and Meet CRA Objectives
24
Florida Community Bank “While not everyone qualifies for the program, we get inquiries into an array of products which means the phones are ringing more often for more reasons. We have been able to close an additional 10 loans last year with this product attached which could not have been facilitated without the DPA. We are able to use this suite of products to expand our reach in the market and hit key demographics in our CRA development that enable us to broaden our business and CRA goals…”
Taylor McLaughlin, Affordable Housing Specialist
VALUE AND BENEFITS
• Use products to open previously closed doors
• Direct value proposition for public unit relationships
• Local governments
25
VALUE AND BENEFITS
March 2014 - FHLBank Atlanta member hosted a “Real Estate Professional Networking Event” - Over 40 real estate professionals attended!
“Everyone here feels like it was a huge success in reaching our realtors and really getting through to them on the value and importance of these programs. We couldn’t
have done it without you! ”
- Lesley Graham, Georgia Banking Company
Advancing Your CRA Business Development Opportunities
ShaDonte Butler, Community Business Development Manager September 24, 2015 Tampa, Florida
9/18/2015
14
Contact Us for More Information (800) 536-9650, Option 3, Option 1, Option 3 Visit our website at www.fhlbatl.com
BUSINESS DEVELOPMENT ShaDonte Butler– Community Investment Business Development Manager [email protected]
RENTAL TEAM Joel Brockmann – Rental Production Manager Don Billingsley James Monaghan Glenn Stewart Clarissa Weaver
OWNERSHIP TEAM Maxima Sims – Ownership Production Manager Michael Thimsen Richard Mauney Pearlie Jackson Cassandra Madden Greta Hollimon Linda Johnson
Compliance officer pannel
Larry Goldberg
Regulatory update
Meeting Location : The University Club of Tampa - 201 N. Franklin Street, 38th Floor, Tampa, FL 33602
Parking Instructions : Parking is available in the Fort Brooke Garage at the NW corner of Florida and Whiting. The 3rd floor of the garage has a covered walk- over to the building.
Arrival : Please arrive 5-10 minutes prior to your session’s start time to allow yourself plenty of time to check in and get settled.
Dress : Business Casual. Please also consider bringing a sweater or jacket for your comfort.
CPE: 3.75 hours crcm/3 hours cams (CFE eligible)
September 24, 2015 The University Club of Tampa
Welcome from Saltmarsh & Program Overview Kristen J. Stogniew, Esq., CFE, Saltmarsh, Cleaveland & Gund
1:30 AML, Fraud and BSA from the Perspective of Law Enforcement Professionals Working with Financial Institutions Anita Cream, US Department of Justice Kimberly Lappin, IRS Criminal Investigations Division Special Agent Richard Dunn, Department of Homeland Security
2:30 Break
3:30 Break
3:45 Compliance Officer Panel Sheila Roberts, Crews Banking Corporation Sarah Oliver, Bank of North Carolina Larry Goldberg, Professional Bank
4:45 Regulatory Update, including: Fair Lending, TRID, ACH and BSA Regulatory Focus Kristen J. Stogniew, Esq., CFE, Saltmarsh, Cleaveland & Gund
Keep the Conversation Going! Use #SaltmarshBankTalk before, during and after each session to share your questions,
feedback and event photos!
Richard M. Dunn | U.S. Department of Homeland Security [email protected]
Supervisory Special Agent (SSA) Richard Dunn has almost 15 years of federal experience as a Criminal Investigator/Special Agent. He commenced federal service in 2001 with the U.S. Department of the Treasury, U.S. Customs Service in Queens, New York, specifically JFK International Airport where he primarily worked narcotics and money laundering investigations until January 2008 when he transferred to Tampa, Florida.
While at JFK, Rich was assigned to the JFK Narcotics Smuggling Unit (JNSU) where he was intimately involved in numerous complex investigations that resulted in the identification, disruption, and dismantling of transnational criminal organizations involved in money laundering, narcotics trafficking, weapons trafficking, document fraud, and human smuggling.
In January, 2008, Rich transferred to the HSI Tampa Office where he worked in the Narcotics Smuggling Group until 2010 when he was reassigned to the HSI Tampa Financial Group. During his tenure at the HSI Tampa Office, Rich continued to work complex investigations, which focused on and have subsequently led to the identification, disruption and dismantling of transnational criminal organizations.
In 2014, Rich was promoted and is currently the supervisor in charge of the Financial Investigations Group and the Asset Identification and Removal Group (AIRG).
Kimberly A. Lappin | IRS, Criminal Investigation, Tampa Field Office [email protected]
Kimberly Lappin is the Special Agent in Charge of the IRS, Criminal Investigation, Tampa Field Office. She began her Internal Revenue Service career in 1988 as a Special Agent in Albany, New York. In 1998, Ms. Lappin served as an Instructor at the Federal Law Enforcement Training Center (FLETC) in Glynco, Georgia and was responsible for course development and instruction to new special agents in both the IRS Special Agent Basic Training and FLETC Criminal Investigation Training Programs.
Since 2001, she has held various increasingly responsible management positions including Supervisory Special Agent in Orlando and Senior Program Analyst on the Review & Program Evaluation staff in Washington DC.
In 2011, Ms. Lappin was selected as the Director, of CI’s Office of International Field Operations – EAST. In that position she provided operational oversight and leadership to IRS posts in Hong Kong, London, Frankfurt and Sydney and Europol. Specifically, she oversaw efforts to combat international criminal tax fraud and money laundering for the IRS Posts.
Ms. Lappin has also served as Acting Executive Director and Deputy Director of International Operations.
2015 Financial Institution Compliance Funnel | Saltmarsh, Cleaveland & Gund
Financial Institution Compliance Funnel Speaker Biographies
ShaDonte Butler | Federal Home Loan Bank of Atlanta (FHLB) [email protected]
As Business Development Manager, ShaDonte focuses on cultivating and expanding the Bank’s customer relationships and driving new business to the Bank through its Community Investment Products. Prior to joining the Bank in 2009, she worked in a variety of roles within Fannie Mae’s Single Family Mortgage Division. Her most recent position was Sales Support Manager in which she developed operational efficiencies to increase new customer acquisition and developed effective sales techniques and procedures to successfully position Fannie Mae’s product and technology offerings.
ShaDonte earned a Bachelor of Science degree in finance and economics (summa cum laude) from Fisk University in Nashville, TN, a Master of Business Administration specializing in Finance from Clark Atlanta University and a Master of Science in Building Construction/Residential Development from Georgia Tech.
2015 Financial Institution Compliance Funnel | Saltmarsh, Cleaveland & Gund
Jacquie Moore | Bank of Tampa [email protected]
Jacquie Moore is Senior Vice President, Chief Risk and Compliance Officer of The Bank of Tampa. Jacquie joined the bank in September 2011, with more than 20 years of banking experience.
Prior to joining the bank, Jacquie worked as a Compliance Analyst with the FDIC, performing examinations for state banks in reviewing for compliance with federal regulations. The Bank of Tampa is the only Bank in Florida since 2010 to have received Outstanding CRA ratings (4/2010 as a Large Bank and 7/2013 as an Intermediate Small Institution).
Jacquie holds a degree from Georgia State University and has earned her American Bankers Association (ABA) designation as a Certified Regulatory Compliance Examiner.
Anita M. Cream | U.S. Department of Justice [email protected]
Assistant United States Attorney Anita M. Cream has been the Chief of the Asset Recovery and Victim’s Rights Division (ARVRD) of the United States Attorney’s Office for the Middle District of Florida since 2002. The ARVRD is responsible for handling all civil and criminal asset forfeiture cases for the district, running the Suspicious Activity Report Review Teams in Orlando, Jacksonville, Tampa and Ft. Myers and federal debt collection for the district and coordinating with victims and witnesses in criminal cases.
Prior to becoming the ARVRD Chief, Anita served in the Criminal and Civil Divisions. She has handled bankruptcy, defensive and affirmative civil cases as well as criminal tax, drug, fraud, and money laundering cases.
She graduated from Georgetown University Law Center, cum laude, in 1995. After graduation, she worked as a litigation associate at Akin, Gump, Strauss, Hauer & Feld, LLP, in Washington, DC before joining the U.S. Attorney’s Office.
Financial Institution Compliance Funnel Speaker Biographies
2015 Financial Institution Compliance Funnel | Saltmarsh, Cleaveland & Gund
Kristen J. Stogniew, Esq., CFE | Saltmarsh, Cleaveland & Gund [email protected]
Kristen is a shareholder in the Financial Institutions Advisory Group of Saltmarsh, Cleaveland & Gund. Prior to joining Saltmarsh, she served as executive director of Stogniew & Associates, a consulting firm started in 1980 by her father, Gerry Stogniew, where she oversaw the provision of internal audit, loan review and compliance audit services to community banks and credit unions in Florida, Tennessee and California.
Kristen has been providing legal advice and audit services in regulatory compliance and financial institution operations since 1995. At Saltmarsh, she continues to provide risk management, policy and procedure drafting, compliance audit and monitoring, and related consulting in areas such as: BSA, AML model validation, loan and deposit compliance, marketing and retail delivery, trust, governance, UDAAP and ACH. Kristen also provides one-on-one mentoring and customized training to staff, management and Financial Institution Directorate.
Sheila Roberts, CRCM | Crews Banking Corporation [email protected]
Sheila Roberts is the Chief Compliance Officer for Crews Banking Corporation, which includes Wauchula State Bank, Wauchula, $604,123 in assets; First State Bank or Arcadia, Arcadia, $138,550 in assets; Charlotte State Bank & Trust, Port Charlotte, $304,505 in assets; and Englewood Bank & Trust, Englewood, $228,408 in assets.
She is the Privacy Officer for First State Bank of Arcadia and Charlotte State Bank & Trust and the CRA Officer for First State Bank of Arcadia, Charlotte State Bank and Trust and Englewood Bank & Trust. Sheila has served as BSA Officer for First State Bank of Arcadia, Charlotte State Bank & Trust and Englewood Bank & Trust.
Larry Goldberg | Professional Bank [email protected]
Larry Goldberg is a compliance executive with more than 30 years of government and bank experience. He is a former examiner with the Federal Reserve Bank of Atlanta and has served as Chief Compliance Officer and Risk Management Director for several Miami-based financial institutions having both domestic and international operations. Most recently he was Chief Compliance/Risk Management Officer for Coconut Grove Bank.
Larry attended the University of Florida where he earned his Bachelor of Science degree in Business Administration. He holds several certifications within the banking industry related to compliance including Certified Regulatory Compliance Manager (CRCM), Certified Anti-Money Laundering Specialist (CAMS), Certified Risk Professional (CRP) and Anti-Money Laundering Specialist (AMLP). Larry is also the current President of the South Florida Compliance Association.
Sarah Oliver, CRCM | Bank of North Carolina [email protected]
Sarah is a career Compliance Officer who began working in consumer compliance over 10 years ago. She has worked for institutions ranging in asset size from $130 million to $15 billion. In addition to assisting with compliance exams performed by the FRB of Atlanta, she has experience working under the direct purview of the CFPB. Sarah currently works as the Compliance Testing Manager for the Bank of North Carolina. She is particularly disciplined in FCRA, Social Media and Credit Card compliance matters and is also a recent graduate of the FBA’s School of Banking, earning academic honors there.
She is passionate about the banking industry and publishes monthly compliance-related posts written in simple language on her LinkedIn blog - https://www.linkedin.com/in/saraholivercrcm
AML, Fraud & bsa from the perspective of law enforcement
professionals working with banks
Anita Cream
9/18/2015
1
ShaDonte Butler, Community Business Development Manager September 24, 2015 Tampa, Florida
Disclaimer
Certain information contained herein has been prepared by FHLBank Atlanta from third-party and market data and using analytical tools it believes to be accurate and reliable. No warranty, expressed or implied, however, is made concerning the completeness or accuracy of such information. The analysis and applications contained herein are provided for illustrative purposes only and are based on certain assumptions that FHLBank Atlanta believes to be reasonable. Different assumptions, however, may lead to materially different results. Additionally, past performance and experience with respect to similar financial products may not necessarily be indicative of actual results.
The information, analysis, and applications contained herein should not be relied upon as a substitute for your own business judgment and independent review. You should consult your own regulatory, tax, business, investment, financial, and accounting advisors, and should perform your own suitability analysis, before entering into any transaction or structure described herein. Sophisticated financial products are risky and are not appropriate for all persons. FHLBank Atlanta is not a registered investment advisor and does not advise persons on the advisability of investing in, purchasing, or selling sophisticated financial products or the means by which any such product may be utilized.
Nothing in the information herein should be considered an offer to sell or a solicitation of an offer to buy any securities or derivative products. FHLBank Atlanta is not obligated to update or keep current the information or applications contained herein. FHLBank Atlanta may own or have a position relative to certain securities or other financial instruments discussed in this information or used in this analysis. Neither FHLBank Atlanta nor any of its directors, officers, employees, agents, attorneys, or representatives shall have any liability for any loss or damage arising out of the use of all or any part of this information.
All information is indicative of the time this presentation was written.
2
9/18/2015
2
• Connecting the Dots – Scale and Impact
• CRA Business Development Rental and Ownership Products
• CRA Business Development Services
• How Can We Help You Succeed?
Our Discussion Today
9/18/2015
3
• Lack of capital for small businesses
• Spurring economic development to create permanent jobs with a livable wage
• Lack of capacity and resources for communities and organizations working to meet the needs of constituents
The Challenges
5
• Clearly illustrate how your bank’s CRA philosophy is integrated into the culture
• Commitment from management and the board
• Shared accountability
• Develop Performance Context • Assess community needs • Match bank products and services with
community credit needs • Develop performance and rating goals and
objectives • Track and monitor performance
Develop an Effective Strategic Plan
7
• Framing Performance Context • Description of institution
• Description of assessment area(s)
8
9/18/2015
5
• Develop a community profile for each assessment area (AA) • Bank capacity and business strategy • Operating changes since the prior CRA exam • Geographic footprint • Demographic data • Economic conditions • Competitive environment
* Highlight what you do well!
Performance Context
• Review demographic data
• Contact community partners
• Assess community needs
• Public Entities • Agencies or affiliates of federal, state and local
government • Economic and community development • Small Business Administration • Housing Authorities
• Private Entities • Community Development Financial Institutions (CDFIs) • For profit and nonprofit housing developers • Community Development Credit Unions • Community Housing Development Organizations
(CHDOs) • Minority and Women-Owned Financial Institutions
Assess Opportunities
• Analyze lending practices and loan products
• Analyze retail banking products/services
• Analyze your bank’s position in the market (competition)
• Are there any gaps between community needs and the types of credit and services available at your bank?
9/18/2015
7
Service Opportunities
Multi-Bank loan pools Deposits or grants to CDFIs, CDCs, CDEs, Minority and women- owned financial institutions
Technical assistance to nonprofits, CDFIs and CDCs
Loans to CDFIs or CDCs for housing or small business lending
LIHTC or NMTC projects
Loans for affordable rental housing
Contributions to local CD organizations
Foreclosure prevention counseling
How Can FHLBank Atlanta Help Advance Your CRA Success Story?
9/18/2015
8
Value of Products
• Assist you in achieving your lending and services objectives in your CRA exam
• Borrowers’ incomes must be less than or equal to 80% of AMI
Value of Services
Loan Growth
Value of Services
Products • Homeownership products
drivers in your market area
• Realtors, developers, local government, HFAs, and nonprofits
• Connecting you to the military community
• Marketing assistance
• Structured partnerships
• CRA consultations
17
Structured Partnership Products
Expanding Your Eligible Customer Base New! FHLBank Atlanta AHP Income Limit Methodology and Calculator
18
• Selects the greatest of four calculation methodologies
• Point-and-click Calculator automatically provides the highest income limit
• 548 of 599 counties in the Bank’s district (91%) now have a higher income limit!
Old Methodology Highest of New Methodology % Higher than Old Methodology
$38,150 $46,150 21%
9/18/2015
10
Sellers contribution $0
Closing Costs $2,836
81.6%
99.2%
Business Value: Reduce Loan Risk in Transactions Ownership Example - Transactional Level
19
Sellers Contribution $0
Closing Costs $7,680
91.9%
99.8%
THE PRODUCTS
(LIHTC)
• Reduces project debt service • Which thereby permits a reduction in
project rents to enable affordability
• Use of Funds • Acquisition
THE PRODUCTS
$500,000 AHP Subsidy 55 rental units
Waterfront Rescue Mission – Pensacola, FL $500,000 AHP Subsidy
100 rental units
Acquisition $590,000 $590,000
Soft Costs $1,716,414 $65,000 $106,161 $2,063,862
Other Costs $2,143,311 $547,815 $858,851 $3,014,288
Total Development Budget $13,610,007 $612,815 $1,100,000 $11,897,192
Total Debt – First Mortgage $1,100,000
Member Loan-to-value (LTV/Cost) 8.1%
Member LTV/Cost if AHP converted to Debt
12.6%
DCR 1.36
DCR if AHP converted to Debt (7% for 15 years) 0.71
21
Rental Example: Extend Credit and Reduce Loan Risk
“AHP has the ability to fill funding gaps.” – FHLBank Atlanta Shareholder
THE PRODUCTS
22
• Shareholder sponsored the AHP Competitive application for the direct subsidy • Which could be CRA-eligible Service Opportunity
• Tenants in project are all at 80% or below of area median income • Which would position project as a CRA-eligible activity
THE PRODUCTS
9/18/2015
12
Services
• Connections to Business Drivers: FHLBank Atlanta has a database of more than 4,000 developers, realtors, contractors, nonprofits, etc. that can be shared with shareholders
• Can be sorted by local market
• Marketing: FHLBank Atlanta provides templates homeownership product marketing
• Templates available at www.fhlbatl.com
• Direct assistance with shareholders
• Education and Outreach: FHLBank Atlanta partners with shareholders to lead webinars, host business development events, and conduct other outreach to grow their business
THE SERVICES
23
Success Stories: Leveraging AHP to Grow Business and Meet CRA Objectives
24
Florida Community Bank “While not everyone qualifies for the program, we get inquiries into an array of products which means the phones are ringing more often for more reasons. We have been able to close an additional 10 loans last year with this product attached which could not have been facilitated without the DPA. We are able to use this suite of products to expand our reach in the market and hit key demographics in our CRA development that enable us to broaden our business and CRA goals…”
Taylor McLaughlin, Affordable Housing Specialist
VALUE AND BENEFITS
• Use products to open previously closed doors
• Direct value proposition for public unit relationships
• Local governments
25
VALUE AND BENEFITS
March 2014 - FHLBank Atlanta member hosted a “Real Estate Professional Networking Event” - Over 40 real estate professionals attended!
“Everyone here feels like it was a huge success in reaching our realtors and really getting through to them on the value and importance of these programs. We couldn’t
have done it without you! ”
- Lesley Graham, Georgia Banking Company
Advancing Your CRA Business Development Opportunities
ShaDonte Butler, Community Business Development Manager September 24, 2015 Tampa, Florida
9/18/2015
14
Contact Us for More Information (800) 536-9650, Option 3, Option 1, Option 3 Visit our website at www.fhlbatl.com
BUSINESS DEVELOPMENT ShaDonte Butler– Community Investment Business Development Manager [email protected]
RENTAL TEAM Joel Brockmann – Rental Production Manager Don Billingsley James Monaghan Glenn Stewart Clarissa Weaver
OWNERSHIP TEAM Maxima Sims – Ownership Production Manager Michael Thimsen Richard Mauney Pearlie Jackson Cassandra Madden Greta Hollimon Linda Johnson
Compliance officer pannel
Larry Goldberg
Regulatory update