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
I have a question regarding loans that we purchase and service: Our Lending Compliance person was reviewing loans purchased and noticed that a loan was missing a GFE. From a compliance standpoint, are we required to follow-up to obtain the GFE and any other missing documentation? How does missing documentation on purchased loans sit with the examiners?
I am looking for a worksheet that can be used to determine whether a loan is a Section 32 mortgage. Do you know of any such worksheet?
Mandatory Flood insurance requirement on a loan with three properties as collateral. Only one is in a flood zone, however the value of the two that are not in the flood zone will more than cover the loan amount. What would be the amount of coverage to require the customer to purchase? The appraised value of the improvements, replacement cost seems to be only for residential property and this is a commercial building. The loan amount if $3,000,000.
If we did a preapproval and denied the preapproval but did not have an address at the time what do we put for census tract number and MSA?
Is there a matrix out there (Mary Beth probably has one!) that charts APR issues like if a fee falls into what category: fee, finance charge, and prepaid finance charge, or exempt/excluded? I tried to sit down with Reg Z and make one for our bankneedless to say, I am now emailing you.
Do we have to do the new insurance disclosure with denials?
If a customer comes in and deposits cash of $5,698.00 in one account and that same day makes a withdrawal of cash from a different account belonging to that same customer for $5,000.00. Those two amounts aren't added together for CTR purposes are they?
Is there a simplified summary of the current, pending HOEPA changes/regulations, pertinent to a mortgage nondepository lender?
I have a question about the rules on bank solicitation or sale of insurance products. From what I understand, there have to be two disclosures. One disclosure when a customer APPLIES for a loan and the other disclosure if the customer's application is approved and they decide to purchase credit life. Both disclosures have to be given orally and in writing. Do we have to get the customer to sign a document stating that they have been given the disclosures?
I've heard there is an Iowa state regulation that prohibits turning down an Iowa loan applicant because of bankruptcy. What prompted that legislation? What are acceptable reasons for a turndown?