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
<a href="http://www.bankersonline.com/articles/v05n14/v05n14a2.html">There is an article by Lucy Griffin on FCRA, ECOA, and Adverse Action Notices.</a>. In talking to the FDIC, who referred me to the FRB issuance dated March 2003, Reg B now states that we do not need to send a separate adverse action notice to the co-applicant if his/her consumer credit report was used to deny a joint credit application. The FRB states that when a person agrees to be a co-applicant, there is a general understanding that information will be shared between the applicants. Therefore, we do not need to inform the primary applicant that there is an "ineligible co-applicant" and send a separate notice. The FDIC is asking me to find out what information you are referring to in the above article by Lucy Griffin.
As the new compliance officer at an OCC-regulated bank that is under a formal agreement, I am uncertain what to do upon discovery of non-monetary compliance issues. Should the bank be required to correct violations, or should the violations be documented and the bank put systems in place that correct these types of violation going forward?
Would the Fannie Mae and/or Freddie Mac Desktop Underwriting and Loan Prospector systems be considered credit scoring systems for the purpose of Reg B? In particular, would these systems be subject to the Reg B “gray band” requirements as outlined in the Fed’s most recent staff interpretations?
Is the brochure, "Buying Your Home - Settlement Costs and Helpful Information" required specifically for the purchase of a primary residence?
Where can I find rules to determine which items on a Good Faith Estimate are prepaid finance charges?
I ask this with no small amount of trepidation, but I must know, is there a law or reg which specifically addresses making loans to illegal aliens? Not one person I've spoken with can answer the question. I've always assumed it wasn't possible.
Can closing costs be rolled into the loan amount on a home equity loan (closed end)?
A loan officer here is wanting to set up an escrow account, on a commercial mortgage, that is to pay income taxes. He wants the money to be part of the monthly payment, and once a year we would transfer the money to the customer's DDA for the customer to pay the income taxes. Is there any reason why this can't be done, and if it can, what needs to be disclosed? Also, would an analysis need to be done yearly for this?
Is there a difference in points and origination fees? Should they both be reported on the 1098 tax form?
Reg B and Intent to Apply for Joint Credit Question. Thank you for the wonderful clarification with the article on Reg B Roundup. Our team and attorneys have discussed at length the best way to establish a person's intent to become jointly liable for a credit obligation at the time of application. This regulation change impacts products differently based on the product process but I’m particularly interested in understanding what other lenders are planning to do to satisfy this change when taking applications over the phone or internet. We are checking with other industry contacts. Do you have any more specific guidance on phone applications for consumer finance (Auto, unsecured)?