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Page 7 Volume 8, Issue 2


Deputy Commissioner is one of ‘40 Under 40’


Deputy Bank Commis- sioner Susannah T. Mar- shall has been selected by Arkansas Business as one of 40 professionals in the state under age 40 who warrant recognition for their achievements. Members of the publi-


cation’s annual “40 Under 40” were profiled in the June 13 issue of Arkansas Business. The 40 honorees were selected from a list of more than 300 nomina- tions, Editor Gwen


KEATING Continued from Page 6


for an electronic debit transaction will be the sum of 21 cents per trans- action and 5 basis points multiplied by the value of the transaction. The provision is effec- tive on October 1, 2011. The Board also ap-


proved an interim final rule that would allow a fraud-prevention upward adjustment of up to 1 cent per transaction. After the final rule was issued, the Association issued a response from Keating.


“While price controls


remain an anathema to free market principles, the Federal Reserve has taken a significant step in reduc- ing the harm that could have resulted from the proposed rule,” Keating


Moritz explained in the issue.


“Since the nominations


process isn’t perfect, and neither are we, we make no claim that these are ‘the most’ impressive or ‘the most’ promising young leaders in the state,” writes Moritz. “But I think you’ll agree that each one is someone the readers of Arkansas Business need to get to know.” Marshall, 39, is one of


two deputy bank commis- sioners who manage the


said. “We will continue to aggressively advocate for remedies that will mitigate any harm caused by this regulatory action.” The interchange provi-


sion of Dodd-Frank ex- empts financial institutions with less than $10 billion in assets.


Groups representing


smaller banks argue, how- ever, that its members could lose revenue if net- works establish separate fee levels that prompt mer- chants to accept only debit cards with the lowest inter- change fees. Another con- cern voiced is that bigger banks are in a better posi- tion to absorb the impact of lower fees. Other high-priority is- sues for the Association identified by Keating at Day With The Commis- sioner include: ▪ Supervisory expecta-


March 1995. She served as a commercial examiner prior to moving in De- cember 2003 to the Fi- nancial Analyst division. In August 2005, Marshall became supervisor of that division. She was ap- pointed deputy bank commissioner on July 9, 2007.


Michael Pirnique Susannah Marshall


area of bank supervision at the Bank Department and report directly to Commis- sioner Candace A. Franks. Marshall has been at the Bank Department since


tions of a financial insti- tution when there is “excessive or chronic customer use” of an automated overdraft pay- ment program, included in final supervisory guid- ance issued by the Federal Deposit Insurance Corpo- ration on November 24, 2010.


If a customer overdraws his or her account on more than six occasions where a fee is charged in a rolling 12-month period, the FDIC expects the financial institutions it supervises to “undertake meaningful and effective follow-up action,” including contacting the customer to discuss less- costly alternatives to the automated overdraft pay- ment program. Keating said the Associa- tion has discussed this re- quirement with FDIC chairman Sheila Bair sev-


June 30, 2011


Marshall is a commis- sioned senior examiner and a 2002 graduate of the Southwestern Gradu- ate School of Banking at Southern Methodist Uni- versity.


This is the 18th year


Arkansas Business has compiled its list of “40 Under 40.”


eral times, emphasizing that it needs to be re- viewed. When a bank is asked to counsel a customer after six overdrafts, Keating said, “really, I mean, when do I get into the social work business as a banker and when do I get in the business of telling people you shouldn’t commit a crime. Bouncing a check is a crime and with ‘call waiting,’ do you think any- body’s going to pick up the phone anyway to talk about their criminal con- duct?” ▪ Registration of


“municipal advisors” and increasing the 500- shareholder threshold. Section 975 of Dodd- Frank requires a registra- tion system for “municipal advisors.” Concern has


See KEATING, Page 11


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