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
Training the Trainer Materials
I am a finance broker for several financial institutions, and have agreements in place to do business with them. We currently do financing and refinancing on chattel loans with several investors. My contract with one of the institutions states that I will not solicit any of their customers for refinancing. My question is as follows: Would it be breaking the Fair Lending or Fair credit Laws to deny someone the opportunity to refinance through my organization because they, who came to me direct, are financed with a company I do business with currently? I have a lender that is asking me to do this to my customer, and I feel like this is wrong and do not want to participate in this activity. Is this against the law? Where could I find information on this to prove to the lender that this is an improper activity, and is not treating the customer fairly and equally?
We want to start a promotion where we notify customers that they have been pre-approved for a Home Equity loan, what guidance can you provide and what regulation should I look at?
Under Reg B, should the submission of an information package from a potential borrower's counsel or a broker as part of a distribution to several banks in an effort to find interest in a deal be considered an application?
Is it required by regulation that we send out a commitment letter, and, if so, is there a time deadline for doing so?
Are commercial real estate loans Reg B reportable? I worked for one institution where it seemed it never applied, now I work for a different institution that applies all the Reg B reporting requirements. I don't understand why it would be applicable to one bank and not the other. (I am talking about two sizable banking institutions in the Northeast, both banks being in excess of $100 billion in assets.)
I recently attended the deposit compliance webinar on November 3. The presenter's presentation noted front line obligations of "protecting the customer's medical privacy." Can you please explain better this obligation and what regulation the presenter specifically was referencing? Is there any impact on this obligation via-a-vis the new health savings product?
I attempted to visit Fannie Mae's website for an answer to my questions and to no avail, so, here they are. <ol><li>Why is it required to pull two separate credit reports when there are co-applicants involved that are not married?<li>If a joint credit report is pulled in error, what does this affect if anything? (i.e. FICO scoring, non compliance, etc?) </ol>
Are there any compliance requirements for lenders to consider in situations where a borrower is removed from the loan application during loan processing?
We would like to pay employees of an affiliate fees to bring in core deposits to the bank (small state bank). The affiliate is a securities company. What should I worry about at the bank level, if anything? The fee would be $100-$200 determined by deposit size.
I have a question that involves CRA Reporting for community development loans. If we have mortgage loans that are made to LMI borrowers or are in LMI areas, can we include these as community development loans on our CRA report? They are also included on our HMDA report. I know we get credit for these, but my question is whether we should include them on the CRA report to the FDIC as community development loans.