Bio:
Jim Bedsole is the Senior Vice President and Chief Compliance & Risk Officer for BankSouth headquartered on Lake Oconee in Greensboro, GA. Mr. Bedsole has thirty years of experience in managing bank risk, regulatory compliance, auditing,
security, and corporate governance with both regional and community banks. He has a Bachelor of Science degree in Business Administration from The Citadel, The Military College of South Carolina in Charleston, SC. He is also a graduate
of the ABA National Graduate School of Compliance Management. He is a Certified Regulatory Compliance Manager, Certified Bank Auditor, Certified Financial Services Auditor, and Certified AML and Fraud Professional.
Jim is a frequent speaker on the topics of risk management, compliance, consumer protection regulations, auditing, and Internet banking regulation. He is currently the chairman of the Georgia Bankers Association Compliance Committee and the vice chairman of the GBA Compliance School Board. He formerly served as co-chair of the ABA Enterprise Risk Management Working Group for Community Banks and on the ABA Risk Management Forum Advisory Committee. He is a former chairman of the SC Bankers Association Compliance and Regulatory Committee and former chairman of the SC Bankers Association Disaster Recovery Committee. He has served on the faculty of the ABA National Compliance School and the NC School of Banking and is currently on the faculty of the Georgia Bankers Association Bank Compliance School.
He has authored articles appearing in both regional and national publications, including ABA Bank Compliance Magazine, Palmetto Banker and numerous Internet web sites. He is also an active private pilot with an instrument rating.
Areas of Expertise:
Compliance Consulting
Compliance Review
Compliance Seminars
Compliance Training
Risk Management Training
Questions Answered
04/01/2018
We issue credit cards with our bank branding using an outside processor. When a business opens a credit card account and has cards issued to authorized users, who is our customer for OFAC purposes? Any card would be issued with titling of ABC Company John Doe embossed on the card. We currently run OFAC for the business but, not the authorized user.
03/18/2018
We are in the beginning stages of implementing online account opening. We are working with the vendor regarding E-SIGN acknowledgment. Currently, the test environment is configured so that the customer receives a validation code in an email. All of the required disclosures are attached to this email as a pdf. I am of the opinion this does not comply with E-SIGN's demonstrable
consent requirement.
Their response to my concern is as follows:
Our other clients have concluded that by obtaining consumer consent to E-SIGN and confirming the consumer received the email (using the verification code) reasonably demonstrates that the consumer can access the information in the electronic form. The disclosures in the email are PDF files. PDF format is an ISO standard that enable users to exchange and view electronic documents, independent of the environment in which they were created or the environment in which they are viewed or printed, while preserving content and visual appearance. Adobe relinquished control of the PDF format in July 2008 to the International Organization for Standardization to encourage the propagation and dissemination of this common technology. Today all modern operating systems, including mobile, support display of PDF files. Adobe Acrobat Reader is not a requirement to open and view PDF files.
Thus, my question is would you deem this configuration to meet E-SIGN consent requirements?
03/04/2018
We have a business entity, buying a non-owner occupied residential 1-4 unit single family residences. Do we need a 1003 on the individuals and are these HMDA reportable?
01/21/2018
Does TRID apply to HELOC's? Do I need to have LE's out within 3 days of an application?
12/31/2017
My question is regarding earnest money deposits on a residential mortgage real estate transaction. The file contained a copy of cancelled check from borrower to realtor dated 2/23. The application was after that date and intent of notice to proceed has not yet been obtained. Internal mortgage compliance audit cited violation of 1026.19(e)(2) stating check to realtor should have been dated after ITP. I think they are wrong - since that independent transaction happened outside of the control of the financial institution. I don't believe the EMD date preceding the ITP argument has any merit. Am I wrong? Do you have some advice on how to write some fun (but respectful) rebuttal language?
12/31/2017
I am being told I do not need to report to the Board annually on Security. Is this true and, if so, when did that change?
12/24/2017
If I give the appraisal copy to every real estate loan applicant, am I still required to give the Right to Receive a Copy of the Appraisal Report notice initially?
11/26/2017
What regulation (section, paragraph, etc.) states that accounts with a negative balance as a result of utilizing overdraft privilege will be closed after 'X' number of days?
11/05/2017
If we are calling a current mortgage customer to let them know they may qualify for a lower rate with a refinance, are these internal customers required to be ran through the FTC Do-Not-Call list?
10/22/2017
There is some ambiguity regarding LLCs at our institution. We require LLCs to have a TIN, and will allow a SSN for sole member LLCs. We also ask that LLCs register with the VT SOS and provide us with an operating agreement. The pushback we get from customers and sometimes their attorneys is problematic. Are we out of line in our requirements?
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