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.
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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
06/30/2003
Does the HOEPA test apply if I am doing a loan on a mobile home that is the borrower's primary residence but only the title is held as security? No mortgage (only a lien on the title) or land is involved.
06/30/2003
We have a customer who has struggled to make his payments on his mobile home loan. The mobile home is his principal dwelling and the original loan was purchase money. He was past due and we were about to foreclose when he asked if we could renew his note to get it current. He had changed jobs and after checking his income to debt and cash flow, we agreed to refinance the loan. Does the refinanced loan fall under HOEPA?
06/30/2003
What kind of fines and penalties apply if the required HOEPA disclosures were not given to the customer?
06/23/2003
When I was reviewing our new bank disclosure for truth in savings and EFT, I noticed there was a change made on transaction limitations for savings accounts. The disclosure states that only three transactions are allowed instead of the reg's six. Is this considered to still be in compliance since it is less than the reg as long as they allow the six?
06/23/2003
Is there a records retention requirement for loan applications that are withdrawn within 3 business days after the date the application was made?
06/23/2003
Is suspicion of kiting activity a justifiable reason to place an extended hold on an account?
06/23/2003
With regard to the new CIP regulations, will we have to include indirect auto loans in the ID verification process, or can we rely on the info furnished on the application to the original creditor? (aka the auto dealer.)
06/23/2003
Prior to the issuance of the final ruling on the USA PATRIOT Act, Section 326, we had already planned to scan photo identity documents on new customers. Since this will not be required under the final regulations, will it be a violation of Reg. B to maintain scanned images of a customer's driver's license or other photo identification document?
06/23/2003
I have been trying to draft procedures to follow the 2004 HMDA rules regarding HMDAreportable preapprovals. One thing the new HMDA regs never seem to clearly state is how far back a lender must look to determine whether an origination started as a preapproval. What I want to believe is that once a preapproval request is denied, withdrawn, closed for incompleteness, or approved but the commitment expires, any future application by the client is a NEW event NOT related to the earlier preapproval request. Example: Preapproval is granted and the written commitment expires April 15. Client shows up on May 12 to start a full application, which later closes. The May 12 application is NOT going to be marked on HMDA as having started with a preapproval, because the earlier preapproval commitment expired before the client showed up to start a full application. (If the Bank chose to report approvedbutnotaccepted preapprovals, there would be two HMDA records reported for this client: the approvednotaccepted preapproval, and the originated loan.) I hope my interpretation is correct; if we have to go back indefinitely to match preapproval requests of various dispositions with future applications, it would become impractical to offer preapprovals!
06/23/2003
For TISA compliance purposes, are CD's and time deposits treated the same or differently?
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