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
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Training the Trainer Materials
Concerning a counter offer on a consumer loan. In this case not mortgage related. To my understanding a counter offer applies when you want to change a term from the original request in order to position the borrower to grant approval. IE reduce loan amount, extend duration of term. Can a counter be used to request a co-signer /endorser to be placed on the loan.
With a comment that states this loan would be granted as long as the added co-signer or guarantor is approved?
Are there possible compliance violations with Regulations B & C and UDAAP if denial reasons are different on the HMDA LAR than what was on the Notice of
Adverse Action? For example: at the time of decline, the denial reason listed on the NOAA was "Other", but when the file was reviewed for HMDA data
validation, the true denial reason should've been a Collateral decline.
A local swim club has applied for a $25,000 loan to do improvements. The flood search shows that the security property (which is one parcel) is in a flood zone. Per the insurance company that insures the swim club, the pump house is not in a flood zone. Using the flood maps, the township engineer says that he will issue an elevation certificate and a letter certifying that the clubhouse on the security property is also not in the flood zone. The pool itself cannot be covered by a flood policy. If our bank gets an elevation certificate and a letter from the township engineer, is this sufficient to warrant our bank putting this loan on without flood insurance?
My institution is beginning an on-line mortgage application process and pre-qualification program. I have some questions with what follow up
procedures should be. #1 Individual sees our site and enters a couple of pieces of information, but does not have a completed application. What
should be our follow up? #2 The individual completes the application on-line but does not follow up within the 30 days with other required information.
Is this an incomplete application? Also, on a prequalification, the individual is notified of being qualified and receives letter stating this
online, but does nothing in the allotted time period. Are we required any documentation be sent to applicant? I know this is a lot of questions, but
there are so many variables. We are trying to set up our procedures. Any other information in regards to on-line application and pre-qualifications
would greatly be appreciated.
If a customer with a 4 year CD with interest paid monthly, after 6 months, decides to have it compound annually, what would be the next date for interest to be paid? The opening date was 1-1-2016.
This question is in regards to collection of demographic information in a face-to-face interview. The applicant checked Mexican under the Ethnicity section but did not check Hispanic or Latino. The loan officer checked Hispanic or Latino and answered "Yes" to "Was the ethnicity of the borrower collected on the basis of visual observation or surname?" Now we are getting validity exception V629. Should the loan officer have checked "No" to the information was collected based on visual/surname?
Can a co-borrower be added to a loan after a closing disclosure is issued?
HMDA - Number of key fields - Out of the 110 data fields, I need to verify the number of key fields for the HMDA Data Fields. I think that the number is 37 but I just want to be certain.
I have a question related to HMDA 2018, specifically around GMI collection methods. We had some correspondent lenders start using the demographic information addendum in late 2017. What rules would apply to collection method of GMI since the application date was in 2017 but the Demo Info addendum was used?
As part of the Reg E Error resolution process, (for an unauthorized debit card transaction), are we required to send a letter to the customer once the case has been investigated to let them know whether provisional credit will be rescinded or not? Currently we are only sending a letter when provisional credit is being revoked, not when the customer is being allowed
to keep it.