Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 39 years. In Jack's 34 years as a trainer over 125,000 bankers (and many examiners) have participated in his live seminars and webinars. Jack's career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by several state bankers associations. He developed and delivered compliance training for the FDIC and OTS for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association. He is also a "BOL Guru."
See all Upcoming and On-Demand training presented by Jack.
In regards to the check box options on an adverse action notice, as a commercial lender, I would like to add “Length of time in business is too short” as we do deny credit to many newly established companies (per our credit policy), so my question is this: Can I create my own reason(s) or are there a specific set of reasons that I need to adhere to? Where does ‘length of time in business too short’ (or verbiage to that effect) fit on an adverse action notice?
If you do a preapproval/prequalification where you have five pieces of information (not the property location) and the customer is approved for an amount but the customer never comes back to the bank. What is the proper procedure in this situation?
If you deny an application because the applicant cannot get clear title on the property what reason would you use on the denial notice (would you create an “Other” reason)?
In a scenario where the appraised value came in low, would an appraisal be considered as 3rd party information?
Is a notice of action taken needed in the case where we choose not to open a deposit account because of information contained in a credit report?
Are regulators concerned about illegal discrimination during the foreclosure surge?
Do these rule apply to small servicers?
Do COVID-19-related activities earn CD credit?
What guidance regarding the surge has been provided by the federal financial institution regulatory agencies?
What is the foreclosure surge?