Co-signer income and fair lending
04/17/2016
Would you explain, please, the difference (if any) in treating income and debts jointly or separately for co-signers vs. for joint applicants?
Patricia is a partner in Cashman Compliance Solutions, LLC. She is responsible for consumer compliance reviews, Bank Secrecy Act (BSA) and Anti-Money Laundering reviews, and compliance and BSA training.
Patricia began her banking career in 1969. She has been the senior operations officer for three Dallas-Ft. Worth area community banks, an assistant examiner for the Texas Department of Banking and managed the compliance/internal audit division of TIB - The Independent BankersBank, one of the largest bankers' banks in the country.
Additionally, Patricia has spoken as a webcast/teleconference presenter for the American Bankers Association (ABA), BankersOnline (BOL) and the Center for Financial Training (CFT), taught a variety of compliance subjects for the Texas Bankers Association (TBA) and ABA at their respective Compliance Schools. She also serves as a BOL GURU and been a speaker/trainer for numerous banks and compliance organizations.
You may contact Patricia via email at plcashman@cashmancs.com.
04/17/2016
Would you explain, please, the difference (if any) in treating income and debts jointly or separately for co-signers vs. for joint applicants?
04/17/2016
We use a third-party service provider to manage some of the benefits of our “Platinum Account”. Are there possible UDAAP issues lurking here?
04/10/2016
Do you see a problem with marketing and/or encouraging our customers to “opt-in” for overdraft protection?
04/03/2016
We are revising our deposit accounts and one account will be titled Free Checking. This product will have e-statements as the default at no charge. Since e-statements are the default, we will charge $3.95 for a paper statement. Is this a concern relative to Unfair, Deceptive, or Abusive Acts or Practices?
05/18/2015
We currently offer two overdraft protection options - one is a transfer from a line of credit and the other is an auto transfer from a deposit account. In either case, we have a disclosed transfer fee of $5.00 per transfer which is charged to the checking account regardless of whether the funding account is the LOC or the deposit account. We would like to increase the fee on existing accounts. Because we charge the same fee (whether it is a LOC transfer or a deposit account transfer) to the checking account is it possible to increase the fee with a 30 day notice to customers like any other fee adjustment? We are also considering an annual fee for this service for both new and existing customers. The annual fee would be charged to the checking account and not to the LOC/funding account.
09/01/2014
Please explain aggregated transactions. I have a business and with three cash deposits all under the reporting limit. One transaction is done by a person and the other two are night deposits. Would I have to mark off aggregated on the CTR?
06/23/2014
Is there a compliance or regulation issue if the property tax disbursement on the Initial Escrow Disclosure Statement does not match the HUD?
06/23/2014
We are conducting an internal audit on RESPA. We have noted several variances on the HUDs with different processors. The section titled Loan terms at the end of the HUD that has information concering the rates and dates and payment dates on variable rate loans is filled out different with each processor. Is that something we need to correct and if so what is the best way to do this. Some are not filled in at all.
10/14/2013
In using a Home Equity Line of credit when doing a purchase of a home, can the closing fees be financed and paid out without waiting the rescission days?
09/02/2013
Must each cashier's check be listed on the Official Checks Log when a customer purchases two or more cashier's checks for cash in excess of $10,000, requiring a CTR?