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
There has been some question about whether after the first year an escrow account is set up if a lender can collect one full year (instead of monthly) of taxes and insurance up front? Can a lender do that according to the Reg? If that is true, can you tell me exactly where to find that language in the reg?
In a question that was posed to Patricia Cashman on 7-19-10 concerning HPML and modifications, she stated that escrow will not apply to a true modification. Could she please show me where that can be found in the regulation. I have looked and can't find this. I have this situation and I need more clarification.
We received a check from an attorney to put into an escrow account for our customer. They can receive draws on the check, but only as the work is completed. Can we put a hold on these funds and be in compliance? What suggestions do you have?
Under Reg O, must a director disclose his role as a director of another bank as a related interest, even if this bank is outside of the metropolitan statistical area of the bank in which he is filling the questionnaire?
We are doing a consumer construction loan to complete the primary residence. We have a loan amount of $333,000 of which $156,000.00 is going to pay off the first and second mortgage on their current residence, with $177,000.00 going toward completing the construction on their new home. Is this HMDA reportable because we are satisfying a mortgage, even though this is a construction loan? What disclosures are required since we are taking a first mortgage on their primary residence and a first mortgage on the construction home? The term is twelve months interest only, and we are not doing the permanent financing.
If a loan matures with no new money and we do a modification for the renewal, do we have to set up escrows?
What code is used on the bank's HMDA LAR to report an application that is denied due to too many recent inquiries? Should Code 3 or 9 be used?
In 10/09, a customer refinanced a home equity loan, no cash out. Does that mean he cannot do another loan involving his primary residence for at least twelve months, due to “once a home equity, always a home equity”, or is the twelve month rule just on the original loan, not a no cash out refinance of the balance? Would he be eligible for a reverse mortgage or HELOC at this time, or does the original home equity status of the loan prevent those options?
I am wondering about the consumer disclosure aspect of the Fair Credit Reporting Act. Under time of notice, it says that one may report before or no later than thirty days after reporting it to the credit bureau. If I give them notice when they take out the loan, is that prohibited under the section 623(a)(7) B.2 (Time of Notice)?
I have a borrower who applied for a commercial loan which her parents guaranteed along with her, due to her income being insufficient. The loan was declined. Do I have to send an adverse action letter to each of the parents as well, since they were guaranteeing the loan, or just to the borrower?