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
03/05/2001
Please give some feedback on the following: Would regulators find this a violation to Reg. D? For very good business customers, a bank wants to have a savings account and a zero balance checking account. Monday through Thursday, all checks that pay on the checking account create an approved overdraft. On Friday night enough money is transferred from the savings to cover the overdraft. End result is checking starts out the week at zero and funds are only swept from savings once per week or four (maximum five) times per month, within the reg. D limit.
03/05/2001
We outsource billpayer services are we responsible forerrors under Reg. E, or is the third party provider responsible for the errors when the account is debited, but payment is not received?
02/05/2001
I have installed the BlackIce Firewall on our internet PC at the bank. Yesterday it detected an intruder and successfully blocked them. It gave me their IP address but no other information was available. I have reported it to the President, what else should I do? Do I need to call the FDIC or just document that it happened? BlackIce provides a way to see where it came from and all it told me was Asian-Pacific origin. This is a new process for us and has me somewhat on edge.
02/05/2001
Help! We just crossed the magic threshold of having 50 employees. I am told this makes us subject to the affirmative action laws and requirements. Are there some common mistakes that companies typically make in the affirmative action area? We don't want to get nailed.
02/05/2001
We have a customer who has applied for a home loan but does not qualify because ofher credit history. Her brother has offered to help her by guaranteeing her loan. the loan officerwould feel better if he was co-borrower. What are the legal differences between a guarantor andco-borrower when it comes to trying to collect on a debt? and will there be a fair lending problemif we deny this loan because we insist on a co-borrower?
02/05/2001
Is there any law or regulation that would prevent a Bank from accepting only interest on a mortgage loan for a monthly payment and then attaching the additional amount due to the end of the loan term?
02/05/2001
Can you provide some guidelines for establishing a good second review program?
02/05/2001
Regarding RESPA: I need to know what is the "proper" way to base fees on mortgage loans so that we do not violate any laws. Is it proper to base "points" (we are the mortgage broker in these cases) on the amount of the loan request? I think it is, instead of based on the interest rate. For example: Up to $150,000------1% $150,000 to $300,000------.75%Over $300,000-------.50% I think that is a safer way to price, rather than basing the fee on the interest rate (higher rate = higher fee)
02/05/2001
FRB hotline has indicated that only applications that are resubmitted unchanged can be considered as reinstated any changes would equate to a new 2nd application. This seems impossible to practice any change in loan amount, counteroffer renegotiations, etc. Ideas?
02/05/2001
If a customer has a repossession and there is a deficiency after sale of collateral, and the customer was notified of the balance owing, is there a time frame that we are required to keep any correspondence regarding the balance owing or a time frame that the individual must dispute the balance reported to the credit bureau?
Pages