Dan is Vice President and Compliance Officer for The Peoples State Bank with its main office located in Ellettsville, IN and supporting nine branches in surrounding communities. The bank is a privately owned bank that began its existence in 1904.
Dan entered the financial services arena in 1974 when he went to work for Commercial Credit Corporation. He worked eighteen years with Bank One and three years with the Indiana University Employees Federal Credit Union. In addition to serving as a Compliance Officer, he has served as a Collection Officer, Consumer Loan Officer, Commercial Loan Officer and Loan Operations Officer. His primary duties falls within lending compliance, training and consumer loan reviews.
He attended Three Rivers Junior College in Poplar Bluff, MO and Arkansas State University in Jonesboro, AR. He is also a graduate of the ABA Bank Card School, ABA Commercial Lending School and ABA National Truth-in-Lending Compliance School.
I have a HMDA LAR issue on Commercial - Non originated loans. I have received several edit notices - "Q648: If action is 1,2,3,4,5,7 or 8 then the first 20 characters of the ULI should match the reported LEI" when validating my HMDA LAR. These loans are non-originated HMDA Commercial where the ethnicity is "NA". Is this a known issue or something new?
We are in the process of developing a Jumbo HELOC product. There would be no fees associated with this product, but there is an annual fee of $90, interest-only payments and the balance would come due in 5 years. Considering the balance due in 5 years, would this product be subject to Ability To Repay?
It is my understanding that we have 30 days to notify the customer of our loan decision when denying the request. My question is, does the letter date have to reflect the same date of denial? I had a loan officer deny a mortgage loan within three days of application to avoid early disclosure requirements, but then the application was re-activated and the lender made a second decision with a later date. This second decision date makes the denial notice reflect more than three days from the application date.
I have a closed-end consumer 1-4 family refinance with new money being loaned. This loan has a right of rescission. Am I to collect interest on the refi loan to the date of the loan or the day it comes out of rescission?
Is there a time limit on the construction phase of a one-time close construction-perm loan? In the old days, Reg Z limited the construction phase to 12 months but I'm unsure what apples now.
Our institution is based in Missouri, but we offer an online savings account. We are wondering about what state laws we use for charging dormant/inactive fees to accounts? Missouri Law is that once an account is inactive/dormant for twelve months we can charge a fee up to $5.00 a month. Then after five years of inactivity, the account is considered abandoned and will need to be sent to the State Unclaimed Property department. If a customer from different states opens accounts online with us, do we abide by Missouri Law or the state law which they reside in?
If a home equity loan application is not decisioned within 3 business days and preliminary disclosures are not sent out within those 3 business days, does the application need to be canceled and a new application keyed in? That is our current practice and it's a nightmare for HMDA monitoring submissions.
Can you do a Change In Terms on a mortgage construction loan, increasing the loan amount and charging additional fees (Orig, Title Inc, Flood)? If so, what disclosures required are required or would the loan need to be re-closed as new loan?
Our bank sells credit life and offers it to our clients. Is the credit life sale disclosure required to be signed by the applicant. Is there such a disclosure with no signature requrement?
How are investment loans for multiple dwellings reported? Do we just pick one of the addresses and report that census tract? Example: I have a refinance with 3 separate dwellings as collateral, all on one loan.