Bio:
Mr. 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 42 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.
Questions Answered
07/15/2002
We are considering adding mortgage applications and possibly home equity applications to our internet banking site. If we do this, what are the requirements for diclosing properly? Are there sites containg disclosures that could be downloaded by hyperlink with the applications or some kind of electronic acknowledgements? How do other banks disclose with online applications?
07/15/2002
When converting a check payable to a business to a Cashier's Check, can you deduct the Cashier's Check fee directly from the amount of the face value of the check before issuing?
07/15/2002
Is it a RESPA violation for a mortgage lender to pay a % of the loan commission to the realtor if the realtor actually takes the loan application and is disclosed on the settlement statement?
07/15/2002
Our Consumer Lending unit received the following response to a recent audit. "According to the regulation, a bank may pull a credit report on a person if they have a permissible purpose. An application for credit is considered a permissible purpose. When the Contact Centers take applications over the telephone (he doesnt mention anything about the Internet) they are only speaking with one of the applicants, but if the application is joint, credit bureaus aer obtained for both applicants. Without talking to the joint applicant, the bank can not be sure that the second individuaal is aware of, or wants to apply for a loan. If a co-applicant does not want to be an applicant on the loan, the Bank would not have a permissible purpose for obtaining the credit bureau. It is recommended that the Consumer Lending Dept require that all parties on a loan application be made aware that a credit bureau will be obtained." I realize that this is only a recommendation, but this team believes because a compliance auditor wrote this, they need to act on this recommendation. Is there some litigation that suggests we need to do this? I simply can not find anything, anywhere that states we are required to verbally inform a co-app that we are going to pull a cbr. What am I missing here? Is this a business decision and if so, based on what? If its written somewhere, I would like to see it. What are other institutions doing?
07/15/2002
We are a federally charted bank with offices operating in different states. Do we follow state or federal law for allowable loan fees on consumer, residential mortgage and commercial loans?
07/15/2002
When a customer transfers money between two accounts at our bank via their home computer using our bank's internet web site, are these transactions covered under Reg E?
07/15/2002
Is there a requirement for an annual audit of the ATM? I keep hearing it come up and cannot locate a reference.
07/15/2002
If the rescission notice is not provided or the threeday rescission period is incorrect, does providing the notice after disbursement of loan proceeds eliminate the threeyear rescission period as provided by Reg Z?
07/15/2002
Mandatory Flood insurance requirement on a loan with three properties as collateral. Only one is in a flood zone, however the value of the two that are not in the flood zone will more than cover the loan amount. What would be the amount of coverage to require the customer to purchase? The appraised value of the improvements, replacement cost seems to be only for residential property and this is a commercial building. The loan amount if $3,000,000.
07/01/2002
We had a customer ask us if we wanted to search his briefcase before he made a deposit and entered the safe deposit area. We said "No". We have policy and procedures for the safe deposit box area, but they do not address a search. Because of acts of terror do you have any suggestions for the possibility of searching a customer's belongings such as passing a wand over the bag or satchels before allowing entry into the safe deposit box area. Banks do not know what is kept in a customer's box. What about his privacy? Is this an issue for other banks?
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