Bio:
Lucy is Editor of Compliance Action and President of Compliance Resources, Inc., a company offering compliance support and services to banks. She is also a Senior Associate of Paragon Compliance Group, a company dedicated to providing compliance training. She has more than twenty-five years of experience working with regulatory agencies and financial institutions. Her extensive work experience with regulatory agencies includes the Federal Home Loan Bank Board, the Board of Governors of the Federal Reserve System, and the Federal Trade Commission. As the manager of the Compliance Division of the American Bankers Association, she worked directly with several of the association's banker committees and with regulatory agencies to identify compliance priorities, and to produce resources and programs.
Areas of Expertise:
Compliance Action Newsletter
Compliance Consulting
Compliance Seminars
Training the Trainer Materials
Questions Answered
11/05/2001
Lucy Griffin explained to our Minnesota Bankers compliance group that we must not keep photo copies of picture IDs in loan files because of a possible Reg B violation. However, we also do this when we open new accounts (it could be helpful in cases of identity theft, or just so staff will recognize new customers). We also do it when we make a credit card cash advance for noncustomers, as we have experience identity theft there. Can we do this in nonloan situations and not run afoul of Reg B or other regs?
11/05/2001
This question concerns RESPA. If a loan is secured by 2 14 family residences, one already owned and one purchasing, and is for 12 months interest only to give customer time to sell one of the houses is that covered by RESPA?
11/05/2001
I am looking for a list of the most current bank policies that must be approved by the Board of Trustees.
11/05/2001
If you have a flood determination that is 5 yrs. old and renew the loan (on the same property, no new money), a new determination is done 3 days after the renewal are you still covered by the earlier determination?
08/06/2001
How do banks intend to monitor their service providers to confirm that they are maintaining appropriate security measures to safeguard the bank's customer information? We are looking for a practical, reasonable way to do this.
08/06/2001
What is the difference between a cosigner and a guarantor?
08/06/2001
Are there any specific requirements as to the number of days a loan must be past due before a late charge can be charged?
08/06/2001
What compliance regulations apply to a loan to purchase a primary residence secured by vacant land titled in a business name?
08/06/2001
We have established a mortgage company subsidiary of the bank. Is there any legal way around the prohibition of paying tellers for referrals of bank customers to the mortgage company? Does a referral, either verbal or using a referral form, require an immediate affiliated business arrangement disclosure?
08/06/2001
Under the GLB Privacy Act this question was posted May a teller continue to record our customers' account number on the reverse side of a check when cashing a third party check for example Our customer Bob has a check made payable to him drawn on Joe Schmoes' account at another bank. When Bob cashes that check our teller records Bobs' account number under his endorsement. .Is this operation covered by Section 216.15(a)(2)(ii)?
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