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.
Areas of Expertise:
AML/BSA Independent Audits
In a situation where our collection department is pulling a credit report in order to approve a short sale or other action and the account isn't 30 days delinquent should we be sending an adverse action notice if we decide not to approve the request?
Borrower applies for a refinance. Original application was based on a value that would be 80% LTV. Appraisal came back a little low. LO goes over options with borrower that would include PMI on the loan. Borrower thinks about it and calls back the next day and indicates they do not wish to proceed. Is this a denial or withdrawn by applicant?
We want to place a mortgage ad and use the following: If the interest rate is over 4.00% on your home loan, you may be able to refinance at a lower rate. Are there specific disclosures that would have to be made in this scenario or is it fine as is?
The tax stamps amount changed on the initial GFE because the Lender did not carefully read the P & S, so the lender did a change circumstance, so she could change the fee for the state tax stamps. Is this allowed?
Where do I go to find a good definition of "best practices" for a new employee as it relates to BSA/AML?
If two individuals own a dwelling and have a loan that is secured by the dwelling and one purchases the other's interest in the property, with a dwelling secured loan, is that reported on the HMDA LAR as a Refinance or a Purchase?
We are currently compounding interest daily on certain accounts at our bank. We are changing to monthly but not until after our 30 day notice has been provided to our customers. My question is: are there any forms available to help me out? Can someone help me by giving me the phrases that have to be in the notice in order to be in compliance?
I need clarification on what constitutes a multi-family dwelling for HMDA purposes. I have a loan that has 5 stand alone townhouses that are listed on one deed. Is this truly a multi-family for HMDA reporting, or does it fall into the 1-4 family category?
Do the annual statement notice disclosures referenced in Regulation Z Section 226.20 apply to interest only loans and loans that the rate changes daily?
We would like to know if an account set up as DBA would fall under the business category with regard to Reg E.