COPYRIGHT
Copyright ©2017 by American Bankers Association. All Rights Reserved. No portion of this publication may be
stored or reproduced in any form without permission. Copyright requests should be made in writing to
Jill Goldman at the following address: American Bankers Association, 1120 Connecticut Avenue, NW,
Washington, D.C. 20036-3971; fax to (202) 828-4548; or email to jgoldman@aba.com.
Editorial Advisory Board
CHAIR
Meg Sczyrba, CRCM
Fair and Responsible Banking
Risk Program Manager
US Bank, NA
MEMBERS
Maureen E. Carollo, CRCM, CAMS
Senior Vice President,
Director of Compliance
Great Plains National Bank
Oklahoma City, Okla.
Kathleen M. Curtis, CRCM
Senior Vice President,
Chief Compliance Officer
and BSA Officer
Capital Bank, NA
Rockville, Md.
William (Wylli) J. Foote, CRCM
National Manager and
Fair Lending Officer
Toyota Financial Services
Torrance, Calif.
Marcia E. Geike, CRCM
Vice President, and Senior
Compliance Officer
Home State Bank, NA
Crystal Lake, Ill.
Thomas Healy
Chief Compliance Officer
Ally Bank
Midvale, Utah
Bonita G. Jones
President
Bonita Jones & Associates, LLC
San Francisco, Calif.
Thomas G. Pareigat
General Counsel
Bancorp, Inc.
Minneapolis, Minn.
Nicole. R. Peoples, CRCM
Regional Compliance Officer
Central Bancompany
Blue Springs, Mo.
Maureen Prentice
Compliance Manager
Ally Bank
Charlotte, N.C.
Carl G. Pry, CRCM, CRP
Managing Director
Treliant Risk Advisors
Washington, D.C.
“This publication is designed to provide accurate and authoritative information in regard to the
subject matter covered. It is sold with the understanding that the publisher is not engaged in
rendering legal, accounting, or other professional service. If legal advice or other expert assistance
is required, the services of a competent professional person should be sought.”
—From a Declaration of Principles jointly adopted by a Committee of the
American Bar Association and a Committee of Publishers and Associations.
PUBLISHER
Laurence Price
(202) 663-5378
lprice@aba.com
EDITOR
Laine Crosby
(866) 297-0742
lcrosby@abaeditor.com
ART DIRECTION
Bono Tom Studio, Inc.
studio@bonotom.com
ADVERTISING SALES
Chris Capistrant
(202) 663-5216
ccapistr@aba.com
WEBSITES
www.aba.com/bankcompliance
http://magazines.aba.com/bcmag
http://magazines.aba.com/bcnl
MAILING ADDRESS
Address all articles, letters, advertising
inquiries and other correspondence to:
ABA Bank Compliance
American Bankers Association
1120 Connecticut Avenue, NW
Washington, D.C. 20036-3971
SUBSCRIPTIONS
For information about your subscription,
or to subscribe, call ABA Customer
Service at (800) BANKERS or
(202) 663-5087; or fax to (202) 663-7543.
$300—ABA Member Price*
$450—Nonmember Price*
2—5 subscriptions—save 15%
6—10 subscriptions—save 25%
11—20 subscriptions—save 35%
21—25 subscriptions—save 45%
26+subscriptions—save 50%
SINGLE/BACK ISSUES
$50—ABA Member Price*†
$75—Nonmember Price*†
*AL, AZ, CA, CO, DC, FL, GA, HI, IL, IN, K Y, MA, MI, MO, NC,
NJ, NY, OH, PA, RI, SC, TN, TX, UT, WA, WI, WV, and WY
residents add appropriate sales tax.
†Issues older than six months are half price.
REPRINTS
Article reprints are available in
quantities of 100 or more. For more
information, contact Lindsay Wilson at
The YGS Group at (717) 430-2225.
POSTMASTER
ABA Bank Compliance (ISSN 0887-0187) is
published six times per year (bimonthly)
in the USA by the American Bankers
Association, 1120 Connecticut Avenue
NW, Washington, DC 20036-3971
Postmaster: Send address changes to
American Bankers Association, 1120
Connecticut Avenue NW, Washington,
DC 20036-3971. Periodicals postage
paid at Washington, DC and additional
mailing offices.
Are You a Certified Regulatory
Compliance Manager (CRCM)?
aba.com/CRCM