Pub. 4 2014-2015 Issue 5

O V E R A C E N T U R Y : B U I L D I N G B E T T E R B A N K S - H E L P I N G C O L O R A D A N S R E A L I Z E D R E A M S March • April 2015 17 K. Tyler Leet, director of risk & compliance for Computer Services, Inc., too, advised banks to be wary of potential com- promises. “It’s not ‘If I get hacked or have an incident,’ it’s ‘when I get hacked or have an incident. You need to be prepared for that.” He noted that every person in a bank – or organization – is a potential target of social engineering crimes, such as phishing. “Every one of you has a target on your back.” CBA President and CEO Don Childears spoke of more pleas- ant targets – including regulatory reform – when he addressed the crowd about CBA’s advocacy efforts at the federal level. “It is a more favorable environment for our issues to be presented and addressed,” he said, noting that power is more balanced in the federal legislature. He advised caution, however, because challenge exists around anything lawmakers perceive as “controversial,” including the Dodd-Frank Act. A trio of attorneys troubleshot the new mortgage rules imposed by DFA, telling banks “the best regulation is self-reg- ulation.” Daniel Bray, an attorney withHusch Blackwell told the group, “There is no question, at least anecdotally, that credit is tighter due to these rules.” The trio, which included Kristin Godfrey, a partner with Stinson Leonard Street LLP and Brad Dempsey, a partner with Faegre Baker Daniels, encouraged bankers to review rules and make comments on them. “We need to be affirmative that these promulgations fit with existing statutory structure in Colorado,” Godfrey said. Also during the meeting, Michelle Hemerle, managing di- rector of enterprise governance risk and compliance with FIS, a speaker on managing BSA and Operation Choke Point, broke the news to the 70 attendees that FDIC distanced itself from Operation Choke Point, with new guidance, calling the move “good news.” In part, it reads, “ [A]s a practical matter, it is not possible for a financial institution to detect and report all potentially illicit transactions that flow through an institution,” the agency said. “Isolated or technical violations ... generally do not prompt serious regulatory concern or reflect negatively onmanagement’s supervision or commitment to BSA compliance.” The agency issued the guidance reiterating that it does not prohibit nor discourage banks with appropriate riskmanagement systems from serving customers with risk profiles that the bank is capable of handling. To view presentations made by speakers at the conference, visit the CBA website. n Contact: Tennyson W. Grebenar Stephen T. Johnson Karen L. Witt 303.623.9000 | www.LRRLaw.com Albuquerque | Casper | Colorado Springs | Denver | Las Vegas | Phoenix | Reno | SiliconValley | Tucson With a national reputation for our financial institutions practice, our goal is to assist clients in structuring and operating their institutions to meet business objectives and regulatory requirements. Our Financial Services Group can help your business run smoothly. Experience works. Experience works.