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, firstname.lastname@example.org, or visiting https://www.bankersonline.com
Joint application is received by the bank with one applicant having excellent credit and the other having terrible credit. For AAN purposes, if we provide the specific reasons for turndown to the terrible applicant such as repossession, delinquent past/present credit obligations with others, etc. and then provide an AAN to the excellent applicant, we should re-state repossession, delinquent credit obligations, etc. on the excellent applicant’s AAN as well - even though these reasons don't specifically apply to the excellent applicant himself, but are the primary reasons for the turndown. Correct?
We use combined DTI for underwriting purposes. Regardless of whether joint applicants are married, unmarried, living in the same household, etc. we would need to be consistent with this underwriting practice and consider combined DTI? We shouldn’t look at individual DTI on unmarried joint applicants who for example don’t live at the same household?
Can we do an internal raffle (selling tickets for a chance to win a prize) to benefit a non-profit organization?
How long should we keep complaint letters?
Can a bank who's general practice is to pay provisional credit at day 10 provide it early under special circumstances for a customer?
If the bank has already closed out a dispute claim because the 90-day time frame was up and provisional credit was made final, the bank cannot take funds back if the merchant provides credit after that time?
Are we required to provide a confirmation letter when a dispute is received? Are we required to provide a confirmation letter if we determine there was fraud and the temporary credit is permanent?
Can we advertise a drawing on social media only?
We have a procedure built into our loan program, in which loans with a co-signer are assessed an additional .50% rate increase. Co-signed loans are set up for individuals with limited or no credit file, not for individuals with derogatory credit. The individual co-signing on the loan must have excellent credit. Recently we found a situation where the application was submitted as joint applicants (with joint intent completed), but we structured as a co-sign loan, rather than just looking at the loan as a joint loan, and so we assessed the additional .50% rate increase. Could this practice be considered discriminatory?
Does vehicle voluntary surrender apply in conventional close-end loans?