Privacy among applicants
07/05/2020
If credit is denied because of issues related to only one applicant, for example a charge-off, can we disclose that reason to both applicants, and do both applicants get an Adverse Action Notice?
Andy Zavoina
Bio:
Andy Zavoina, CRCM, is an Executive Vice President and Chief Relationship Officer with the Glia Group, Inc., best known for its interest in BankersOnline.com. He joined Glia and BOL in 2003.
Mr. Zavoina has been in finance and banking for 35 years. Over 20 years were with a two-bank holding company which had $534 million in assets, 89 branches spanning Texas and nearly 500 ATMs. He managed loan workouts, has been a consumer, commercial and real estate lender, managing those departments, as well as being his banks first Webmaster. He was responsible for compliance -management, -auditing, and -training for both banks.
Andy is a frequent webinar presenter for BOL Learning Connect and a key contributor to conferences put on by BOL Conferences, Inc. In addition, Andy teaches live presentations at state association schools and regional compliance organizations across the U.S. and has served on the faculty of national banking schools. He has written articles and lectured on many facets of compliance, the use of the internet and technology as a tool, as well as compliance in cyberspace.
As a BankersOnline Guru, Andy assists banks in every day, and not so every day, compliance questions on BankersOnline, BankCompliance.com and other organizations.
Mr. Zavoina is a recipient of the American Bankers Association’s Distinguished Service Award for his involvement and accomplishments in the field of regulatory compliance management. He is a past Chairman of the ABA’s Compliance Executive Committee, the Editorial Advisory Board for the ABA Compliance Magazine and served as a member of the ABA’s Compliance School Board. He also served on the Texas Bankers Association's Compliance Committee.
He is a graduate of the ABA National Commercial Lending School, National Compliance and National Graduate Compliance School and is a Certified Regulatory Compliance Manager with the Institute of Certified Bankers.
You can reach Andy on the Internet by using his e-mail address, andyz@bankersonline.com, or visiting https://www.bankersonline.com
Mr. Zavoina has been in finance and banking for 35 years. Over 20 years were with a two-bank holding company which had $534 million in assets, 89 branches spanning Texas and nearly 500 ATMs. He managed loan workouts, has been a consumer, commercial and real estate lender, managing those departments, as well as being his banks first Webmaster. He was responsible for compliance -management, -auditing, and -training for both banks.
Andy is a frequent webinar presenter for BOL Learning Connect and a key contributor to conferences put on by BOL Conferences, Inc. In addition, Andy teaches live presentations at state association schools and regional compliance organizations across the U.S. and has served on the faculty of national banking schools. He has written articles and lectured on many facets of compliance, the use of the internet and technology as a tool, as well as compliance in cyberspace.
As a BankersOnline Guru, Andy assists banks in every day, and not so every day, compliance questions on BankersOnline, BankCompliance.com and other organizations.
Mr. Zavoina is a recipient of the American Bankers Association’s Distinguished Service Award for his involvement and accomplishments in the field of regulatory compliance management. He is a past Chairman of the ABA’s Compliance Executive Committee, the Editorial Advisory Board for the ABA Compliance Magazine and served as a member of the ABA’s Compliance School Board. He also served on the Texas Bankers Association's Compliance Committee.
He is a graduate of the ABA National Commercial Lending School, National Compliance and National Graduate Compliance School and is a Certified Regulatory Compliance Manager with the Institute of Certified Bankers.
You can reach Andy on the Internet by using his e-mail address, andyz@bankersonline.com, or visiting https://www.bankersonline.com
Contact info:
You can reach Andy on the Internet by using his e-mail address, andyz@bankersonline.com, or visiting http://www.bankersonline.com.
Questions Answered
How to Report Purchase of 6 Properties on 1 Loan
07/05/2020
How do I report the purchase of 6 properties on one mortgage loan with a combination of 9 leased apartments plus 28 bedrooms with shared bathrooms that are rented weekly or monthly?
Credit Card Promotion-Waive Annual Fee
07/05/2020
The bank is considering a credit card promotion for a period of 90 days that will waive the annual fee for the life of the credit card. A customer must apply for the credit card during this time frame to be eligible. It will not be advertised externally. Must the credit card application be altered or can we leave the annual fee on the app in case other customers take the application with them? What other compliance requirements exist for this type of promotion?
Discrimination against the majority
06/28/2020
Has there been a case where a lender tried so hard to assist minority applicants that it had a fair lending issue with majority applicants?
Customer Notices and Brochures
06/28/2020
My question pertains to customer notices and brochures. I thought that if a bank posts one notice or brochure in another language it must post all notices and brochures in that language. In other words, if we do one sign in a second language (say Spanish), do we need to post all signs and/or brochures in Spanish?
AAN? We don’t make those loans.
06/21/2020
During the PPP loan programs we had many requests, but we were not participating? These are commercial requests and would be subject to Reg B. Were adverse action notices required?
Recurring Charge on Closed Credit Card-Bankruptcy
06/21/2020
A recurring charge was processed on a credit card that was closed due to bankruptcy. It had originally been denied and then was allowed a few days later. Is this allowed per regulations?
Requirements for Changing Online Passwords
06/21/2020
Our examiners made the bank change customers passwords to expire on online banking every 60 days. Of course, customers do not like this. Can you tell me what the requirements are on this?
Compliant E-SIGN agreements
06/14/2020
We are going to offer E-SIGN agreements. We have a vendor with a turn-key application. Is that good enough to get us going?
Record Retention for Charged Off Checking/Savings
06/14/2020
How long do banks have to keep records of charged off checking and savings accounts that are paid in full? How about if no amounts have been collected?
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