Who is an "insider"?
02/26/2017
Who is an "insider" for purposes of Regulation O?
Jack Holzknecht
Bio:
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.
Areas of Expertise:
Compliance Seminars
Contact info:
Questions Answered
Community reinstatement into NFIP
02/26/2017
Is it possible for a community to be reinstated into the NFIP once it has been suspended?
Flood compliance in suspended communities
02/26/2017
May a financial institution make a building-secured loan in a nonparticipating community under the NFIP? ja
Insider overdrafts
02/26/2017
What restrictions does Regulation O place on overdrafts?
Reg E doesn’t say so, but
02/26/2017
Regulation E’s “Procedures for Resolving Errors,” along with that section’s Commentary, neither addresses nor prohibits banks from requiring helpful documentation such as police reports or signed and notarized affidavits. Are such actions are OK?
Overdraft program changes
02/19/2017
For those banks with an automated overdraft protection program, such as bounce protection, does a switch from a ledger-balance method to an available-balance method for the purpose of determining an assessment of an overdraft fee create any consumer issues?
Redlining is a hot topic
02/12/2017
Is the concept of “redlining” still an issue in 2017?
Which credit bureau to disclose
02/12/2017
If you use a vendor that provides credit scores from all 3 bureaus and you only use the score/reasons from one bureau for the denial, do you use that specific bureau's name and address or the actual vendor that supplied the report for your adverse action notice?
Applicants on maternity leave
02/05/2017
May a lender delay the processing of a home loan application because an applicant is on maternity/paternity leave?
Adverse action reasons
02/05/2017
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 or is 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?
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