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
On the HUD1, I've always understood that the Settlement/Closing date must be no later than the note date. Recently, a lending officer gave me a differing opinion. To get a definitive answer, I called one very knowledgable person who told me that "The completed HUD1 must be given to the borrower no later than settlement, with settlement occurring when the note and trust deed are signed by the borrower". To get a second opinion, I called another very knowledgable person who told me that the settlement/closing date may be later than the note date because settlement occurs when the funding happens.
When advertising a tiered deposit product, can we promote the highest tier APY in the body of the ad and then disclose all of the tiers APY at the bottom?
With interest rates continuing to decline, is it permissible to give a 30 day notice to current HELOC customers and place a floor rate?
Is a bank required to provide Sale of Insurance disclosures on mortgage loans in which PMI insurance is required?
Does the Right of Rescission apply to a mobile home loan?
We have a difference of opinion at our bank regarding the CRA public file. Should each branch have its own public file or just the main office?
Does the BSA require that the Board of Directors approve a bank's BSA program on an annual basis? If so, where is that specified in the reg?
My bank has a mortgage department (not a separate company) that closes loans in the bank's name, then sells the loan to the secondary market. It is very common for the bank to finance the construction of a personal residence that has been pre-approved for permanent financing through our mortgage department. Our compliance officer advises that since the mortgage department is not a separate company and they close their loans in the bank's name, this type of financing is considered permanent to the bank and we (the bank) should produce GFE's and Early TIL's. We have been disclosing as she advises, but have been disclosing the terms of the construction financing, not the permanent. Now for my question. Is this incorrect? If so, if we disclose permanent terms and the mortgage department discloses permanent terms, isn't this double disclosure? Another issue is that we (the bank) don't always know the terms of the permanent (rate, term, etc.) when the construction financing is processed. Can you offer any guidance on how to handle situations like this?
I have an insurance company that is telling me it is impossible for them to issue a flood insurance policy on a construction loan before the slab is poured. Is this true?
How long do we have to file a CTR once the transaction has occurred?