Independent Banker - October 2020 - 7

FROM THE TOP
" Community bankers have
answered the call of duty
to do what's right by our
customers. For this exam
cycle, let's just make sure
we're covering our bases. "
Noah W. Wilcox
Chairman, ICBA
Noah Wilcox is president, CEO and chairman of Grand Rapids State Bank
and its holding company, Wilcox Bancshares Inc., Grand Rapids, Minn.
A nation in crisis requires an emergency
response, and community bankers have answered
the call.
This year, as turmoil arose from the COVID19
pandemic, community bankers stepped in
to respond to the needs of our communities. As
this health crisis continues to wreak havoc on our
economy, we fi ght on. We remain in the trenches
for our customers, granting accommodation
requests and helping them navigate changes to
their business models.
In fact, as the pandemic persists, we have
extended our eff orts to both business and consumer
clients. We have identifi ed ways to help,
not for our banks' gain, but because it's in our
DNA as community bankers to do what's morally
right. For this, we should be heralded, not penalized,
but that's precisely where the friction lies:
How examiners interpret our actions may not
align with the vision behind them.
Since August, I've participated in weekly calls
with my regulator, and new issues arise in each
one. For example, when we discussed Paycheck
Protection Program loans, I argued that because
they are backed by the government, they technically
shouldn't be treated as risky assets on our
books, but I'm not certain our examiners will see
it that way. The message from Washington-get
the funds immediately into the hands of the businesses
that need them-may get lost in translation
when the fi eld exam staff dive deeper into details.
My Top
Three
Here are my
top three tips
for bankers in
preparing for this
year's exams:
1. Develop
and follow a
documented
methodology for
accommodations.
2. For
consumer loan
accommodations,
be aware of
consumer
protection and fair
lending laws.
3. Remember
you're writing for
the regulator. Keep
it succinct and
straightforward.
Then, as we respond to consumer accommodation
requests, we're hearing cautionary counsel
regarding consumer protection and fair lending
laws. Regulators want to see that we have a
methodical process in place to evaluate every
request and that we assess each one through a
consistent lens. While fairness and consistency
are the primary goals, we're also relationship
bankers who work to do what's right by our customers.
But given the regulator's signals, it seems
that doing what's right needs to be documented.
So, as we explore the topics of regulation and
compliance in this month's issue, let's consider
the need to document as a constant theme. For
example, how you approach accommodations,
how you assess the accommodation request and
how you evaluate the risk will be scrutinized.
In short, we must have a standardized process
that demonstrates that our decisions relative to
these accommodations are safe, sound, prudent
and appropriate.
Our actions speak for themselves, but documentation
can back that up. Our hearts are in
the right place, and community bankers have
answered the call of duty to do what's right by
our customers. For this exam cycle, let's just
make sure we're covering our bases.
Connect with Noah @NWWilcox
independentbanker.org Q 7
http://www.independentbanker.org
Independent Banker - October 2020

Table of Contents for the Digital Edition of Independent Banker - October 2020
