Colleagues, Fellow Professionals and Friends, 

"Honor is a harder master than the law,"
wrote Mark Twain. But Twain never read the TRID regulations. On the cusp of the TRID effective date, many a loan system provider, many a banker, many a closing agent, many a bank examiner, and dare I say, many a CFPB regulator, are still trying to master this law. 

This coming October 3 is a date five years in the making -  five years, really! It all began on July 21, 2010 with the Big Bang, otherwise known as the moment when the Dodd-Frank Wall Street Reform and Consumer Protection Act was signed into being. From there, a mass of symposiums, design discussions, prototypes, and focus groups, congealed into a primordial soup, if you will, out of which crawled a Proposed Rule on July 9, 2012. This Rule went through a series of survival tests before evolving and standing erect as the Final Rule on November 20, 2013. The Final Rule has now been ranging to and fro across the land, morphing in the process through CFPB amendments, while being closely studied by a massive group of experts - all trying to grasp every requirement and nuance.

Have we all mastered it? No, but at least we still have our honor (well, mostly), along with the hope of promised enforcement "sensitivity" (where law abounds, grace should superabound). And, if after so long in the trenches of trying to read and unscrew the inscrutable, the day should come when grace has run its course and an examiner finds a TRID violation in our midst, we shall have a ready answer from Twain,  "We have an insanity plea that would have saved Cain."

If you need help with TRID, call us. We have a team of expert compliance consultants that draws on five decades of financial industry experience to help you meet regulatory burdens with confidence. We are dedicated to keeping current and understanding compliance in the banking industry. We also have our CompliancePro® system that is content-ready to test your compliance with the new rules.

We serve over 350 banks, credit unions and other financial institutions in 35 states - and counting!

I hope this edition of  BankLine has many items of interest for you. 


James W. Bruce, III
CEO and General Counsel, American Bank SystemsAcknowledge
Born in Tulsa, Greg attended Pittsburg State University, the largest printing school in the nation, where he received his bachelor's degree in printing management and received a minor in business administration. He has been married to his wife, Kathy, for the past 35 years. Together, they have raised three children and are now the proud grandparents of five.
Aside from being a banking industry expert, Greg is also a certified Oklahoma state police officer and volunteers at the local police department on weekends. Also while away from the office, Greg enjoys riding his Honda Goldwing Motorcycle.
Greg is also an active member of the Oklahoma Reserve Law Officers Association, the Blue Knights (a law enforcement motorcycle club), the Goldwing Riders Association and the Printers Industry of America.  
CompliancePro: Sophisticated Yet User-Friendly 

Sophisticated enough for a large compliance department yet simple enough for a single user, CompliancePro helps you manage your compliance risk and monitoring efforts with confidence! With user-friendly features, which can be customized to suit your unique needs, CompliancePro  simplifies those things that make managing compliance so painful - like too much to do and too little time and too many regulatory changes to monitor. CompliancePro gives you a system that automates much of your workload with content updates from our team of compliance experts.  

Saving both time and money, CompliancePro reduces or eliminates external auditing and consulting fees, distributes monitoring activities to the appropriate departments and individuals, generates reports for management, board of directors and examiners, and identifies compliance issues and tracks corrective actions.
Consistently maintained and updated to reflect the latest regulatory changes, CompliancePro serves as the ultimate compliance assistant - all at an annual cost that is less than hiring a compliance associate.

Check out these recent posts to our Compliance Blog by our very own team of compliance specialists.
CompliancePro® Client Alerts for Regulation and Law Changes
By: Cody Roberts
Posted September 28, 2015
ABS clients have come to expect (and receive) great customer service. How do we always achieve this? By constantly exploring ways to keep our clients informed of new regulatory developments. That's why we're introducing these new alerts for CompliancePro clients.

CompliancePro is ABS' fully automated browser-based software system that enables institutions to manage and monitor compliance performance efficiently and effectively. It serves as the compliance assistant that positions institutions to optimize performance, while minimizing expenditures of both time and money to assess, manage and monitor compliance risk by product or service. And as regulations change, CompliancePro is updated to provide accurate monitoring procedures for each institution.  [Read More]
What IS a Business Day?
By: Elva Coffey-Sears
Posted September 18, 2015
While that seems like a simple question to us it just isn't that easy in the world of Regulatory Compliance! According to Wikipedia, "a business day is considered every official working day of the week" and "typically, these are the days between and including Monday to Friday and do not include public holidays and weekends." That's pretty straightforward - but Compliance Officers BEWARE! The definition of the term "business day" varies by regulation.

For purposes of Regulations CC and DD, a business day means a calendar day other than Saturday, Sunday or any of the public holidays specified in 5 U.S.C. 6103(a), including New Year's Day, the birthday of Martin Luther King, Jr., Washington's birthday, Memorial Day, Independence Day, Labor Day, Columbus Day, Veteran's Day, Thanksgiving Day and Christmas Day.   [Read More]
Military Lending Act Revisions
By: Gina Ellis
Posted September 4, 2015
Many banks have procedures in place to obtain a written statement from an applicant to establish military status to determine if certain provisions of the Military Lending Act (MLA) are applicable for consumer disclosure purposes. However, starting on October 3, 2016, banks will have access to a new safe harbor to determine military or dependent status through the Department of Defense (DOD) database or one of the nationwide consumer reporting agencies. [Read More] BANKNOTESEPT

Introducing Our New Automated Attendant System

Here at ABS, we've always taken pride in delivering high tech, high touch support experiences for our customers. "Help," as they say, "is only help if it's what you need when you need it." This is and will always be our focus - to give you the help you need when you need it.
Throughout our history, we've had a full-time receptionist who has become "The Voice of ABS." Our long-time customers may remember Phyllis in this role until her retirement. Over the past few years, Brenda has taken over that mantel. Sadly for us, Brenda has left ABS to return to her first vocation - teaching elementary children.
Since Brenda will no longer be the voice of ABS, we will be introducing a new approach to handling customer calls. First, we will publish a list of Direct Inward Dialing (DID) numbers, so if you have a favorite ABS Associate with a DID number - call that person directly. You can also call a new automated attendant system to get your call to the right person as quickly and efficiently as possible. Be sure to look for this transition in the coming days. We will modify the automated attendant as needed to continue to deliver that high tech, high touch support that has, and always will be, a distinctive of ABS customer care.

2015 BankManager Users Conference 

To register for the conference, please visit: Special room rates are also available at the Sheraton using the ABS group rate code: AJ27AA.
We look forward to seeing you there! InHouseSem

Check out our schedule of upcoming in-house seminars. We hope to see you there! For more information, please contact Mary Cope at

  • Basics Real Estate Loan Documentation, 10/1 InHouseSeminarsVAULTWEBINARSEPT
See below for our exciting schedule of upcoming webinars ahead. For more information, please contact Mikel Dunnagan at
  • Reg. E Error Resolution Basics, 10/8
  • Bank Secrecy Act (BSA) Basics, 10/22
  • Dodd-Frank and the Risk-Based Pricing, Exception, and Credit Score Notice Provisions, 11/5
  • The Basics of Flood Rules, 11/19
  • Home Mortgage Disclosure Act (HMDA) Basics, 12/3 WEBINAR
Cheesy Olive Bread
Provided By: Cindy  Wilhelm, ABS Training Specialist

  • One 6-ounce can black olives, drained
  • One 6-ounce jar pimiento-stuffed green olives
  • 2 stalks green onions
  • 1 stick butter, at room temperature
  • ½ cup mayonnaise
  • 12 ounces Monterrey Jack cheese, grated
  • 1 loaf crusty French bread, sliced lengthwise
  1. Preheat oven to 325°F.
  2. Roughly chop both the black olives and pimiento-stuffed green olives.  Slice the green onions into thin pieces.
  3. Combine the butter, mayonnaise, cheese, olives and green onions in a mixing bowl.  Stir together until thoroughly combined.
  4. Spread the mixture onto French bread.  Bake until the cheese is melted and browning, 20 to 25 minutes  

The mixture can also be refrigerated (up to 2 days) and used as a dip. Great with crackers!
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