Pub. 3 2012 Issue 1

spring 2012 19 Why Banking School? By Donna Atkinson, Director of Education Banks and their employees face numerous challenges, such as increased competition and the economy. A key to overcoming these challenges and distinguishing the abilities of the financial institution is an educated workforce. B ecause education is critical to our professional success, West Virginia Bankers Association works to fill the needs of its bankers through seminars, classes and the highly-recognized West Virginia School of Banking. A two- year program, WVBA’s School of Banking is the premier educational opportunity for our member institutions to educate their employees. Students walk away with practical knowledge for day-to-day use, as well as first-hand knowl- edge of how a bank operates. Extremely affordable, banking school will improve the quality of your employees. Dr. Ed Seifried continues to be the Dean of our School and is one of its greatest assets. The School of Banking meets one week annually for two years and focuses on bank management, leadership skills and strategic planning. The curriculum consists of formal instruction through lectures, case analyses and group discussions. In the second year, the students run their own bank with Bank Exec, a computer-based bank manage- ment program. Through exciting competition, the students determine what decisions must be made to create the most profitable bank in their community. Except for senior man- agement, few individuals in a bank have the opportunity to be exposed to the wide range of operating decisions that are presented in this exercise. A major purpose of Bank Exec is to develop an understanding of the complexities of manag- ing a bank and the need for a consistent set of policies to maintain the growth, profitability and survival of the bank. The Lloyd P. Calvert Graduate School of Banking was add- ed to the School in 2001. Like the WV School of Banking, the graduate school approaches banking from a top man- agement perspective. It is designed to further broaden the participant’s outlook, as well as spark creative thinking and offer a “big picture” view of a bank’s survival and growth. Many of the graduates of the School of Banking will find the graduate school more thought provoking – plus it serves as a refresher to those who graduated several years ago. Applications have been mailed to banks and are currently being accepted. This year’s school is May 20-25, 2012 at the beautiful University of Charleston, directly across the river from the State Capitol. A full brochure and application are available on our website – www.wvbankers.org . Q of adverse action. To meet that requirement in the context of privacy concerns and customer relations, the Fed expects that banks would provide separate FCRA adverse action notices to each applicant, with each notice addressing only that indi- vidual’s credit score. While co-applicants are treated the same for receiving adverse action notices, co-signers (or guarantors) are not. Only “ap- plicants” should receive adverse action notices and co-signers are not considered “applicants” under ECOA or FCRA. In a situation where an adverse action is based solely on the information in a co-signer’s credit report, the applicant must still receive the adverse action notice, but details about the co- signers creditworthiness should be omitted. MODEL NOTICES If any good news can be found in these labyrinthine requirements, it is that the Fed has provided model notices, the use of which provides safe harbor for compliance with Regu- lation B. Included in Appendix C of Regulation B are five model notices, which address the combined disclosures under ECOA , FCRA, and FCRA as amended by Dodd-Frank. CONCLUSION The use of credit scores may be an effective method for under- writing loans, deciding whether to open new deposit accounts or making a hiring decision. But the practice now carries additional obligations for notice and disclosure. If your bank is using credit scores in credit, deposit, or employment decisions, review your processes for compliance with risk based pricing and adverse action disclosures. Q