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.
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Areas of Expertise:
Lending & Operations Compliance Matrices
Organization Health / Culture Consulting & Training
Training the Trainer Materials
We normally perform escrow analysis annually each year in January on all our escrowed loans. It is now February and we realized this was not done. Doing the analysis now, a month later - will this affect anything adversely? We usually give the customers notice 60 days before changing their payments which was usually in March. Assuming we need to wait now until April. Will this affect them in anyway having a 13 month cycle now versus what would normally be a 12 month analysis time frame? And then next year should we keep the analysis in Feb or go back to January which would result in a short 11 month cycle next year?
Is there a matrix that shows training requirements for the different regulations? I know BSA is an annual event, but I'm looking for guidance on Reg O, Fair Lending, UDAAP, etc. and especially for the board of directors.
Is a large bank required to send adverse action notices when a payment due date change or extension is denied for consumer loan products?
What is required in our notice to customers regarding the change to Reg CC?
Please define differences between a withdrawn loan request by the customer and a denial of a loan request by the bank.
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
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?
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.
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.
On an ag/commercial loan, if there are two borrowers, do both need to sign an extension agreement or can just one of them sign and extend a loan?
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?