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
First, I'd like to be sure I understand the terminology. When it's referred to as a "maximum hold = 5 days", it means the funds need to be available ON day #5, or AFTER day #5? (I think it's "on", but want to verify.) Q In regards to Regulation CC, when are the funds available (in this day and age of Saturday office hours)? For example, on a local check, it says "available for withdrawal not later than the second business day following the banking day on which funds are deposited". I deposit my check on Thursday. The actual hold is the remainder of Thursday and all of Friday. My hold ends on Friday. Should I be able to access my hold on Saturday, or only on Monday?
We have opened a branch in a metropolitan area this week. We are now HMDA reportable. When do we begin maintaining the LAR now or January 1st of 2003? Also, we are still classified as a small bank with assets less than $250,000 when we begin maintaining the LAR do we do it for all branches or just for the branch in the metropolitan area?
Is a bank allowed to run a credit report on a customer whose only relationship with the bank is an existing checking account? The account has been open for 5 years and been in good standing.
I was testing some APR Disclosures (on regular payment loans) when I noticed that although there was a "Violation APR is understated by..." message and the APR was understated by more than .125% (the tolerance for regular payment loans), the program was not printing the "Truth In Lending Reimbursement Documentation" sheet. I double checked the data that I had input but still no reimbursement sheet. Has anyone else experienced this situation with the program? Is there some other factor besides the tolerance percentage that determines whether or not reimbursement is required (i.e. loan amount or term)?
What's the simplest way to explain Reg D to Branch personnel?
How do I check the APR calculation on our consumer loans to ensure the accuracy? Is there a website that will do this?
On a home equity loan, if there is anyone over the age of 18 living in the home at the time the loan is approved, do they have to sign the deed of trust even though they are not on the original deed of trust?
With regard to a closed end home equity loan requiring a right of recission, can interest begin to accrue on the date the loan documents are signed or does interest accrual have to begin at disbursement of the proceeds?
Who created the Fed Box? Must it always be used for the required disclosures, or are their alternatives?