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#277612 - 11/19/04 08:41 PM Quick Reg/penalty listing
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,644
The Swamp
I am looking for a brief matrix on Reg/brief description and penalty...anyone have one or know where one is located? (With all these deadlines...I'm looking for one project to cheat on!!! )
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General Discussion
#277613 - 11/22/04 02:49 PM Re: Quick Reg/penalty listing
Pale Rider Offline
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under the Lone Star
Andy and MB did a good summary back in 2001, so it is a litlle dated and may need some additions, but if you do a search on regulatory + penalties, it will be there.
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#277614 - 11/22/04 06:46 PM Re: Quick Reg/penalty listing
Reg Wrecker Offline
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Reg Wrecker
Joined: Dec 2003
Posts: 543
Kentucky
Joker, did you ever find this? If you did, can you let me know where? I tried searching and couldn't find it.
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#277615 - 11/22/04 07:59 PM Re: Quick Reg/penalty listing
RR Joker Offline
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RR Joker
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The Swamp
No, I sure didn't...anyone?
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#277616 - 11/22/04 08:21 PM Re: Quick Reg/penalty listing
waldensouth Offline
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waldensouth
Joined: Nov 2001
Posts: 7,974
FINALLY ABOVE the gnat line
Joker, I put together a penalty list when they increased CMPs due to inflation. It may not be complete, but it's close. I'll e-mail it to your bank address. (don't know how to do attachments on this)
Last edited by waldensouth; 11/22/04 08:57 PM.
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#277617 - 11/22/04 08:29 PM Re: Quick Reg/penalty listing
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,644
The Swamp
Thanks! I have something to share with you as well.
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My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#277618 - 11/22/04 10:09 PM Re: Quick Reg/penalty listing
someone else Offline
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someone else
Joined: Aug 2004
Posts: 3,300
back to my roots
How funny! Here we are discussing CMPs and this just came to me from the OCC. Just thought I would share...
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#277619 - 11/22/04 10:12 PM Re: Quick Reg/penalty listing
Reg Wrecker Offline
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Reg Wrecker
Joined: Dec 2003
Posts: 543
Kentucky
Why thank you!!
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#277620 - 11/22/04 10:17 PM Re: Quick Reg/penalty listing
someone else Offline
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someone else
Joined: Aug 2004
Posts: 3,300
back to my roots
Believe me, it is nice, for once, to be a contributor of info instead of always being the taker!

I am also going to post this to the Lending Forum.
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#277621 - 11/22/04 10:30 PM Re: Quick Reg/penalty listing
Pale Rider Offline
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under the Lone Star
Put Regulatory Penalties in quotes and Andy Z in the poster space and you should come up with the thread. It is dated June 14, 2001 under General Discussion. I just pulled it up with the search engine.
_________________________
Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


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#277622 - 11/23/04 05:02 PM Re: Quick Reg/penalty listing
Andy_Z Online
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Andy_Z
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On the Net
Oh, click me for a violation cost. This list originated with the ABA and the link actually takes you out of BOL to the MoneyPage, for us old folks who remember that. It predated BOL.
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#277623 - 11/24/04 08:51 PM Re: Quick Reg/penalty listing
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,644
The Swamp
Oh Ya'll are the BEST! I hadn't seen any new hits on this thread and it wasn't bold on my screen, but I just decided to see if by CHANCE there was anything new! Oh a goldmine...yes! Thanks Andy Z!!!!!
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My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#277624 - 06/21/05 11:54 AM Re: Quick Reg/penalty listing
Anonymous
Unregistered

Sorry to raise this thread from the dead, but the links don't work anymore. I also can't pull up the June 2001 thread via the search feature.

Any suggestions?

Thanks!

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#277625 - 06/21/05 01:11 PM Re: Quick Reg/penalty listing
LoisLane Offline
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LoisLane
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
I copied the following when it first appeared on BOL. Hope it is what you want:
PENALTIES
The Bank's Board of Directors, Senior Management, and Compliance Officer must be aware that there are substantial civil and criminal penalties which may be assessed against the Bank, its directors, officers, and employees for willful and negligent failure to comply with the many laws and regulations to which the Bank is subject. Some of the severe penalties for violation of (or non-compliance with) various laws and regulations are listed below:
Bank Secrecy Act
Civil penalties for each willful violation of CTR reporting requirements the greater of $25,000 or the amount of the CTR (not to exceed $100,000)
Criminal penalties up to ten years in jail and $500,000 fine
$1,500 per report for other reporting or recordkeeping violations such as filing an incorrect CTR
$500 for negligent violation of any BSA requirement
Loss of Bank charter is possible in extreme cases
Section 311 / 312 USA Patriot Act now increased from $100k to $1 Million.

Regulation B: Equal Credit Opportunity
Punitive damages of up to $10,000 in an individual action;
$500,000 or 1% of Bank's net worth in a class action; plus actual damages, costs, and attorneys' fees
May be subject to enforcement guidelines

Regulation CC: Expedited Funds Availability
Penalty of up to $1,000 in an individual action;
$500,000 or 1% of Bank's net worth in a class action plus actual damages, costs, and attorneys' fees

Regulation D & Q: Reserve Requirements and Interest on Deposits
Civil Penalties based on Bank's ability to pay and severity of the violation assessed under Federal Reserve Rules of Practice or additional reserve requirements during subsequent periods

Regulation E: Electronic Funds Transfer
Penalty of up to $1,000 in an individual action; $500,000 or 1% of Bank's net worth in a class action; plus actual damages, costs, and attorneys' fees
Criminal penalty $5,000 and one year in jail for failure to comply; $10,000 and ten years for fraudulent activities

Regulation O: Loans to Executive Officers, Directors, and Principal Shareholders
Civil liability of $1,000 per day for every day violation remains
Individual penalties may also be assessed against the insider, the Bank, and Bank employees
subject to additional penalties under FIRREA

Regulation Z: Truth in Lending
Penalty of up to $1,000 in an individual action; $500,000 of 1% of Bank's net worth in a class action; plus actual damages, costs, and attorney' fees
Extension of liability in rescindable consumer real estate of up to 3 years, actual damages, and loss of finance charges
Significant potential loss and costs to Bank under restitution guidelines

Violations of Legal lending Limits
Personal and individual liability of directors for loans in excess of limits
Civil money penalties to a maximum of $1,000 per day for each day violation continues
Civil and criminal penalties and sanctions including removal and suspension of officers and directors and loss of Bank charter

Minimum Capital Requirements
Directive, assessment of civil money penalties, or termination of FDIC insurance

Violations of Provision Within Purview of OCC
Assessment of civil money penalties against any officer, director, or other person or removal and suspension of such persons

Violations of Provisions Within Purview of FDIC
Cease and desist orders against the Bank or any individual, termination of FDIC insurance, suspension or removal of individuals
Fines of up to $1,000 per day may be assessed against individuals who violate FDIC order
Certain prohibited practices related to voting rights are punishable by fines against individuals of not more that $5,000 and / or one year in prison
Institutions may be fined up to $100 per day for the employment of individuals convicted of certain criminal offenses without FDIC consent
Civil money penalties of up to $10,000 per day may be assessed for willful violations of prohibited acts

Bank Protection Act
Civil penalties of no more than $100 per day for violation of minimum security devices and procedures provisions
Assessment of civil money penalties against the Bank, its officers and / or its directors for failure to file reports of criminal activity or suspected criminal activity

Real Estate Lending and Appraisals
Removal and / or prohibition orders, cease and desist orders, and the imposition of civil money penalties

Regulation Y: Bank Holding Company Act
Criminal penalties for willful violations and civil penalties for all violations
Embezzlement punishable by imprisonment for not less than two years nor more than ten years and fine of not more than $5,000 per act
Acts of falsification related to bond issuances are punishable by a fine of not more than $10,000 and imprisonment for up to five years

Securities Dealers
Unlawful affiliations subject the Bank to penalty of no more than $1,000 per day; if uncorrected, charter and membership in Federal Reserve System may be revoked

FDIC Improvement Act of 1991
Safety and Soundness Standards
1. Examination assessments may be assessed against depository institutions when affiliates fail or refuse to pay
2. Fines of up to $5,000 for failure to allow examinations or provide required information
International Banking Act of 1978
1. Knowing violations with intent may result in imprisonment for not more than five years or a fine of not more than $1 million per day or both
Truth in Savings
1. Penalty of up to $1,000 in an individual action; $500,000 or 1% of Bank's net worth in a class action; plus actual damages, costs, and attorneys' fees
Submission of Reports
1. Unintentionally late or false / misleading certification subject to penalty of not more than $2,000 per day
2. Not unintentional; not more than $20,000 per day
3. Submissions made knowingly or with reckless disregard for accuracy are subject to penalty of not more than $1 million or not more than !% of Bank's total assets, whichever is less, per day

Federal Sentencing Guidelines
An organization convicted of a federal crime generally must provide restitution to the victims (if any) of the crime; community service may be required
Criminal fines based on the seriousness of the crime and the culpability of the organization
Probation may be ordered for the convicted organization (in addition to restitution and fines)
Additional special assessments, forfeitures, or fees to cover the costs of prosecuting the case


HIGH-RISK COMPLIANCE ISSUES
This list is intended to assist compliance officers in identifying potentially high-risk compliance issues and areas where banks frequently encounter compliance problems. It is not comprehensive and additional research is required to determine the applicability of these requirements to any particular financial institution. The requirements contained in this listing may be pre-empted by more restrictive state regulation. Additional requirements may apply to state non-member institutions.
The following is a list of possible compliance breakdowns or deficiencies which should be considered high risk. Failure to identify and correct such conditions in the early stages may result in the possibility of unnecessary expenses, required file searches, regulatory criticism, restitution, fines, adverse publicity, class action, litigation, or other adverse events.

GENERAL COMPLIANCE:
Failure to maintain an ongoing, effective, documented Compliance Program
Any knowing or willing (intentional) violations of laws, rulings, or regulations
Not addressing significant compliance issues that were brought to management's attention (particularly repeat criticisms) as a result of the work performed by regulatory agencies, or intemal/external audits, examinations, or reviews, or based on information reported by employees or customers
Not obtaining proper government or regulatory licenses or approvals to conduct business or relocate
Not maintaining adequate compliance programs which include:
defined responsibilities
reasonable and documented controls to ensure compliance
appropriate monitoring mechanisms to identify and correct errors
mechanisms to report significant issues to management and the Board
adequate training and awareness programs
an ongoing awareness of procedural, legal., and regulatory changes
Failure to conduct appropriate internal reviews or obtain necessary approvals for new products, forms, systems, disclosures, advertising, and promotional materials

LENDING:
Community Reinvestment Act (12 CFR 25)
Failure to properly document and self-assess the bank's efforts to ascertain and meet the credit needs of the entire delineated community (refer to FFIEC Assessment Factors, note: emphasis on geographic analysis and assessment of lending patterns, and resulting actions taken)
Not adhering to established branch closure policy in reviewing potential closures
Inadequate employee awareness and management/ board involvement
Not meeting CRA technical compliance requirements (file, poster, statement)

Home Mortgage Disclosure Act (Reg C)
Failure to capture and properly report required reporting information in an accurate, complete, and timely manner
Failure to obtain loan purpose and dollar amount
Failure to distribute reports or make publicly available

Equal Credit Opportunity Act (Reg B)
Discouraging credit applications in any manner that may have the effect of discriminating on a prohibitive basis
Discriminatory evaluation or treatment of joint unmarried co-applicants; not combining all income and debt of all borrowers
Incorrect, incomplete, or untimely notices of adverse action
Not disclosing accurate reasons for adverse action
Not properly notifying applicants within 30 days of receiving a completed application
Not providing adverse action notification for business credit when required
Not periodically revalidating credit scoring systems and reviewing appropriateness of the various reasons for decline given
Requiring a spouse's signature on a note or guarantee when the applicant qualifies for individual credit
Not accurately reporting the type of credit extended (joint or individual) properly to credit reporting agencies
Failure to obtain government monitoring information
Failure to properly document specific reasons for decline
Failure to provide appraisals to applicant upon request

Fair Credit Reporting Act (12 USC 1681)
Not disclosing the name and address of a credit bureau reporting agency when used in whole or in part in declining a credit application
Not disclosing information obtained from "other sources" when used in whole or in part in declining a credit application
Inadequate degree of employee awareness consulting Legal Department; post solicitation reviews
Sharing credit bureau reports between banks
Not disclosing nature of "other source" upon request
Improper content or selection criteria for direct mail solicitations
Declining prescreened direct mail solicitations on conditions that are prohibited by prescreening rules
Not accurately reporting payment history to credit reporting agencies

RESPA (Reg X)
Failure to apply RESPA rules to all covered transactions
Failure to furnish the Special Information Booklet and/or an accurate and complete Good Faith Estimate within three days after receipt of a written application.
Failure to provide the Uniform Settlement Statement to the borrower at settlement
Offering prohibited inter-company or third-party incentives for generating mortgages
Failure to provide mortgage servicing disclosures initially and when payment or servicing changes
Failure to perform escrow account analysis
Failure to provide notice of referral for controlled business arrangements

Fair Housing Act (12 CFR 27)
Denying or acting in a manner which has the effect of denying an applicant a home loan on a prohibited basis
Failure to include Equal Housing Lender disclosure in advertisements
Failure to accurately capture and maintain Fair Housing Home Loan Data System information when required

Flood Insurance (12 CFR 22.42 USC 4002)
Not identifying properties that are located in flood hazard area
Failure to require the borrower to purchase flood insurance when properties are located in a flood hazard area
Failure to renew flood insurance during the life of the loan
Non-compliance with flood insurance requirements on dealer-generated mobile home paper
Failure to make proper written disclosure ten days before closing of flood insurance requirement
Failure to ensure borrower has sufficient (or maximum) flood coverage

Truth in Lending Act (Reg Z)
Incorrect or incomplete disclosures to customers, particularly the amount financed or the finance charges resulting in incorrect APRs
Using an incorrect first payment period resulting in incorrect APRs
Not adequately disclosing the method of determining the balance to which the finance charge is actually applied
Failure to properly resolve billing disputes within required timeframes
Failure to follow rescission requirements
Failure to make restitution for overcharges when required by the regulation
Failure to furnish the required disclosure statements on consumer short-term or demand loans which originate outside of Consumer Markets
Failure to update initial disclosure booklets annually (i.e. 15 year index history)
Failure to place rate cap on variable rate loans
Failure to adhere to suspension and termination rules

Fair Debt Collection Practices Act (15 USC 1692)
Harassing or abusing a borrower in the collection of a debt
Using false representation in the collection of a third-party debt or threatening to take action that cannot be taken legally or that is not intended to be taken
Failure to ensure third-party agencies acting on behalf of bank adhere to Fair Debt Collection Practices

HUD Homeowner Counseling
Failure to disclose availability of counseling when loan becomes delinquent
Consumer Leasing Act ( Reg M)
Failure to make required disclosures to the consumer prior to consummation of the lease.
Failure to include required elements in lease advertisements

Collateral (Reg U 17 CFR 240.17)
Non-compliance with lost or stolen securities requirements when accepting securities as collateral
Failure to obtain statement of purpose (Reg. U) on loans for purchase of securities
Failure to report stock of other banks held as collateral when required

Daylight overdrafts (FRB Policy Statement)
Self-assessment is complete, accurate, and reviewed by management and the Board

OREO (OPPO) (12 USC 29.12 CFR 7.3025)
A program is not in place to ensure OREO compliance
Appraisals are not conducted in accordance with OREO requirements
Transactions are not properly recorded on a timely basis

Bankruptcy Code
Attempting to collect a debt post-filing in violation of the automatic stay
Attempting to collect a debt that was discharged through bankruptcy
Allowing pre-petition deposit accounts to remain open a Chapter 7 or 11 is filed

FIRREA Appraisal Requirements
Failure to obtain an appraisal when a new loan is secured by real property (unless one of the exceptions applies)
Failure to obtain an appraisal when a real estate secured loan is renewed (unless the exception applies)
Failure to obtain an appraisal when a real estate secured loan is classified or the real property is transferred to OREO

DEPOSITS:
Bank Secrecy Act (BSA) (31 USC 18.31 CFR 103)
Failure to maintain an effective (board approved) BSA compliance program with all required elements: training, internal controls, annual independent testing, and accountability for monitoring
Failure to file currency transaction reports when required
Filing of incomplete or inaccurate currency transaction reports
Exempting ineligible customers
Not regularly reviewing exemption limits
Not obtaining proper identification for non-customer exchange item purchases
Inadequate degree of employee awareness
Not providing ongoing documented awareness training
Failure to report suspicious transactions when appropriate
Failure to obtain TIN numbers on new accounts
Failure to adhere to the bank's policy on money laundering
Failure to adhere to new account opening/know your customer procedures
Failure to maintain $3,000 cash transaction logs
Employees assisting customers in structuring transactions to avoid reporting (potentially a criminal violation)

Tax Issues on Deposits and Loans (IDTCA)
Failure to obtain the correct taxpayer identification numbers for Form 1099 reporting to the IRS
Non-compliance with IRA reporting requirements
Inaccurate reporting of interest earned or interest paid
Failure to backup withhold when required
Failure to adhere to tax reporting requirements of debt forgiven

Electronic Funds Transfer Act ( Reg E)
Failure to adequately disclose error resolution procedures for EFT disputes
Failure to properly resolve EFT dispute or provisionally recredit the customer's account within required timeframes
Failure to adhere to disclosure and error correction requirements related to preauthorized transfers
Failure to promptly and correctly reverse fees charged in error
Failure to monitor accounts for overdrafts when provisional credit is reversed
Failure to adhere to resolution procedures when credit card is used as debit card

Escheatment (State Law)
Failure to properly report and surrender abandoned property to the state on a timely basis
Failure to make good faith estimate to notify customers on inactive accounts prior to escheatment

Reserve Requirements and Interest on Deposits (Reg D and O)
Ineffective monitoring systems and non-enforcement of limited transaction account provisions (savings and money market accounts)
Any arrangements designed to circumvent the requirements of Regulation D (for example, sweep arrangements)
Permitting ineligible account ownership (NOW accounts)
Failure to collect required penalties for early withdrawal
(Note: Effective with Truth in Savings (Reg DD) disclosure and advertising requirements, the only remaining provision in Reg Q will be the prohibition of payment of interest on demand deposits)

Expedited Funds Availability (Reg CC)
Funds availability disclosures or hold notice requirements are not met
Hold periods exceed specified timeframes
Failure to provide notification of non-payment for a check of $2,500 or more
Failure to establish a training program for applicable employees concerning their duties with respect to compliance with the requirements of the regulation
Failure to make first $100 of deposit available
Inadequate supervisory review or monitoring to ensure holds are placed correctly

Retail Security Transactions
An effective program is in not place to control any retail security sales activities in branches
(Specialized training and compliance procedures are required in this high exposure area)

Posters & Notices
Failure to post or make available the following in an area accessible to the public:
Community Reinvestment Act (CRA) Statement
Community Reinvestment Act Notice
Equal Housing Lender Sign
Branch Disclosure Lobby Notice (Regulation CC)
FACTS about your insured deposit booklet
Notice of annual financial disclosure statement availability, if applicable
HMDA Lobby Poster and Annual HMDA Statement (for selected locations)
FDIC Signs

CORPORATE GOVERNANCE:
Intercompany Transactions
Failure to comply with the requirements involving loans to affiliates
Failure to conduct business between affiliated companies on an arms-length basis
Sale of low-quality assets to affiliated banks
Insider Trading
An effective program is not in place to prevent trading of stock on the basis of inside information with respect to either your bank (if publicly held) or the stock of publicly held customers
Insider Transactions (Reg O)
An effective program is not in place to ensure compliance with insider transaction restrictions. The program should be specifically designed to prevent and periodically review to detect:
Any preferential loans
Prohibited overdrafts (over $1,000)
Extensions in excess of the aggregate limit
Extensions receive the required prior approval
Related interests are properly reported

Regulatory Reporting
Adequate controls are not in place for the preparation of regulatory reports, particularly: written procedures, appropriate documentation, supervisory review, and periodic audit
Not properly completing and submitting regulatory reports within required timeframes, particularly:
Call Reports

Reserve Requirement

FDIC insurance premiums and regulatory assessments

Fiduciary Activities (12 CFR 9)
No appropriate policies and controls in place to ensure compliance with the requirements of Regulation 9 (Particularly uninvested funds; and audit frequency not to exceed 15 months and conducted each calendar year)

EDP
Adequate compliance programs are not in place to address:

Emergency preparedness, disaster recovery and contingency planning PC Standards copyright laws Outside service bureau requirements Privacy considerations when testing live files Information Security Standards

Accounting
Failure to adhere to regulatory accounting requirements with respect to:

Rebooking charged-off assets

Capitalization of interest

Political contributions

Accrual of interest

Reserve for loan losses

Other assets (timely charge off of suspense accounts)

Risk-based capital

Immigration Reform and Control Act (1986)
Failure to obtain properly documented I-9 forms prior to starting employment
Failure to establish follow-up system to ensure expired documentation is replaced

Antitrust/Illegal Tying Arrangements
Prohibited tying of one product or service to a second product or service
Prohibiting a borrower from doing business with a competitor

INTERNATIONAL TRANSACTIONS
Anti-Boycott Provisions (International letters of credit)
Failure to have an effective program in place regarding anti-boycott language on letters of credit financing international trade transactions
Entering into any agreement or issue, open, confirm, pay, or honor any letter of credit containing a prohibited boycott condition or requirement (i.e. uses the terms "blacklist" or "boycott"

Office of Foreign Asset Control (OFAC) (Trading With the Enemy Act)
Conducting prohibited business with specifically designated nationals or countries named by Office of Foreign Asset Control regulations
Transactions with the following countries can cause problems (partial list): Cuba, Iraq, Libya, North Korea, Panama, Vietnam, "Yugoslavia"

OTHER REQUIREMENTS:

Americans with Disabilities Act: Providing reasonable accommodation to disabled employees and customers

Attorney Trust Funds: Reporting overdrafts on attorney trust fund accounts to state bar when required

FDICIA: Regulations will continued to be issued to fully implement the various provisions of FDICIA

Government Loan Programs: Compliance with the provisions of various government insured and/or guaranteed loans programs

Housing and Community Development Act of 1992: Regulations will be forthcoming to implement the provisions of this Act including changes to: BSA, RESPA, and HUD Homeownership Counseling

Legal Orders/Privacy Act: Responding to legal process orders

MSRB and GSA: Municipal and Government Securities Rules

Record Retention Requirements (31 CFR 103): Maintaining customer records for required time periods

Safety and Soundness Rules and Restrictions: Lending limits, dividends, unsuitable investment practices, capital ratios, and so on

Shareholder Communications Act (17 CFR 240.14): Rules with respect to shareholder identification and notification

Uniform Commercial Code (UCC4A): Providing wire customers with disclosures regarding security systems

PATTERNS OR PRACTICE
Informal definition of "pattern" or "practice" taken from a September 7, 1982 OCC letter to a Maryland banker:
A "pattern or practice" has a common cause and occurs consistently.
"Practice" does not necessarily mean a written or unwritten bank policy. It may mean the practice of one or more bank employees with or without bank approval. At the same time, a "pattern" is not determined by the number of violations, but rather relates to the regularity with which a violation occurs. Violations that occur randomly and can not be traced to a common cause would not represent a pattern or practice of violations.
Note: This was a handout at the American Bankers Association's National Regulatory Compliance Conference June 27 - 30, 1993. Obviously, changes have taken place since that time.
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#277626 - 06/21/05 06:02 PM Re: Quick Reg/penalty listing
hobot Offline
Gold Star
hobot
Joined: Dec 2002
Posts: 437
Thanks, Lois! You are great. Good idea too about copying it -- I will. Sorry I wasn't logged in before -- I was the anon in the thread above yours.

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#693142 - 02/26/07 04:38 PM Re: Quick Reg/penalty listing hobot
QCL Offline

Power Poster
QCL
Joined: May 2002
Posts: 6,259
NW IL
Does anyone know who originally created this penalty list?
I would like to use it in training material, but don't want to violate copyright laws.
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#693737 - 02/27/07 02:23 PM Re: Quick Reg/penalty listing QCL
LoisLane Offline
Diamond Poster
LoisLane
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
This was posted to BOL a long time ago. I don't remember if there was a reference attributed to it.

I created a Word file with the data on 6-24-03, so if you did a search from 2001 to June of 2003, you might find the original post to see if there was an author.
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