* Kenneth A. Guenther Executive vice president Independent Bankers Association of America, Washington
Community bankers will have to commit a tremendous amount of time to train staffs and refit their entire deposit operations. Bankers will need to explain the new disclosures and terminology to their customers. Banks face many new expenses including new computer software, statements, brochures, envelopes, postage, software, and storage of records.
Most importantly, bankers must lobby Congress for legislative relief. The IBAA alone strongly opposed this law. The administration's Credit Availability and Regulatory Relief Act of 1992 would relive some of the unnecessary burdens of the Truth in Savings Act. Bankers faced with the burden imposed by the new law should support [the relief bill].
* Richard C. Insley Vice president and compliance officer Signet Bank, Richmond, Va.
The most important thing is to begin with compliance right away and not wait until September, when the regulations go into effect. Banks will have to act quickly as implementation will take many months.
Another stumbling block to watch out for: Many compliance changes will require a high level of approval, which is likely to prove to be a tedious and time-consuming process.
The best advice I can give, depending on the complexity of the operations systems involved and product base in question, is to begin compliance immediately if you have not already done so.
I would also like to stress that it is going to cost. I suggest that bankers keep track of the costs of compliance and implementation so as to provide Congress with the exacting, hard-dollar information as to the incredible costs placed on the banking industry by this undue regulation, so that the banking industry can give supporting evidence on the issue in the future.
* Edmund Mierzwinski Consumer advocate U.S. Public Interest Research Group, Washington
Banks should get ready to tell the truth about their savings accounts. It's a very simple law that shouldn't be a burden.
The intent of the regulation is to make information on interest earned in deposit accounts clear. Banks should refine their disclosures so that the annual percentage yield is prominently displayed. I would suggest that banks use focus group sessions with consumers, rather than lawyers, to see if consumers will understand the new required disclosures.
Banks should discard all methods of balance calculation that don't pay consumers interest on the full amount of the principal in the account each day. The act prohibits such methods, particularly the so-called investable-balance method or the low-balance method. If I were a banker, I would aggressively stop using these methods now before the effective date of the act and let people know I am doing the right thing as a competitive difference between my bank and other banks. Or if I never used them, I would let people know.
* Dane Grant Chief executive officer Lone Star Bank, Houston
This new regulation has caused considerable confusion on the part of banks and regulators. Regulators and bankers disagree with the meaning of the congressional language, so it's difficult to say just what the duties of disclosure are.
For me, it has meant dropping a number of low-end consumer products that might have caused me trouble under the new law.
It has also meant spending a good deal of money and resources on education my management on the duties the bank has under the new law's provisions.
Most of my operations are in low-income and minority areas, and I've tried my best to service these people by offering accessible accounts without service charges, such a a toll-free number for customer service, but this regulation makes the costs of compliance and potential liabilities too costly for me to continue these services.
Since the cost of compliance is high relative to revenues generated on low-end products, such as, for instance, simple $300 loans, this new regulation means that I'll have to scrap small-loan services.
It's the simple working man who's hurt most by this new regulation.