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David A. Dickinson

Bio: 
David's banking career began as a field examiner for the FDIC in 1990. He later became a Loan Officer for a small bank. In 1993, he established Banker's Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker's Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the Center for Financial Training, the American Bankers Association National Compliance Schools and is a frequent speaker at the ABA's Regulatory Compliance Conference. David is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have 3 adult children (none of whom live at home!) & 3 cats (which Dave is allergic to). They live on a lake in Nebraska and when possible, Dave can be found fishing or in the water. David plays the guitar & piano and enjoys singing with Karen. Together they lead worship at their church.

See all Upcoming and On-Demand training presented by David.

Areas of Expertise: 
Audit Services
Compliance Audits
Compliance Consulting
Compliance Review
Compliance Seminars
Lending
Lending & Operations Compliance Matrices
Risk Assessment
Organization Health / Culture Consulting & Training
Training the Trainer Materials
Training Videos

Questions Answered

Collection Method Questions for HMDA

01/26/2020

This question has come up before but I have not seen a clear answer. If the application is NOT taken face to face, how should the collection method questions be answered for HMDA? Code 3 (NA) is only supposed to be for applications where the requirement to report the data does not apply to the covered loan. We would use code 3 on applications where it is an entity. Code 2 (not based on visual observation) would be the only choice that would make sense. What are your thoughts?

Gift Card for Participating in Online Survey

01/12/2020

Can a financial institution offer a current customer a gift card if they participate in an online survey that is sent to their email that we have on file? We are not soliciting a product, just wanting their opinion on our services.

Surplus in Borrower's Escrow Account

01/05/2020

There is a surplus in the borrower's escrow account, but the loan is past due. Can we apply this surplus to his loan? The surplus is $315.44 due to decrease in his homeowner's insurance premium.

APY Disclosure Requirement for a Bonus

12/01/2019

We are advertising a $125 bonus that will be paid when a customer completes a few requirements, including opening 1 of 3 various non-interest and interest-bearing checking accounts, signing up for a direct deposit, and using our mobile banking app. I wasn't planning to disclose an interest rate or APY to avoid the additional disclosures caused by the trigger term. However, when disclosing a bonus, the APY appears to be a requirement. I wanted to verify that we have to disclose the APY (using the term annual percentage yield) and the additional disclosures caused by this trigger term if we are disclosing a bonus. Or, does the APY disclosure requirement for a bonus not apply if we were not planning to disclose the interest rate or APY? Also, are we required to use the word "bonus" in our ad?

Demographic Info Changes at Consummation-HMDA LAR

11/24/2019

For HMDA reporting purposes: An applicant's demographic information is obtained at time of application via an online application process and the data collected is the information input onto the HMDA LAR. But if the applicant changes the demographic info at consummation (at the title company) do we change the data on the LAR from the data collected at application to the data collected at consummation?

Reg DD-Advertising a CD Special on Rate Sheet

11/10/2019

When advertising a CD special on a rate sheet that will be provided to customers, and the ad only indicates the CD special product name with a statement that says, "ask us how to open your CD special," and nothing else, but the CD special has conditions and limitations that the regular CD accounts do not, should a bank disclose on the rate sheet what those conditions and limits are that differ from the regular CD products that are also listed on the rate sheet? There is a fully disclosed addendum for the special that covers the Reg DD disclosure requirements. However, this will only be provided if the special is opened by the customer. My concern is that if the customer only requests the rate sheet and doesn't open the account the customer will not receive the addendum or the full scope of the special on the rate sheet and this may be a little misleading if the customer comes back at a later date to open the special and they find out there are conditions to be met on the product.

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