Bio:
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
Compliance Audits
Compliance Consulting
Compliance Review
Compliance Seminars
Questions Answered
02/15/2010
When is an application subject to RESPA, requiring disclosures to be sent? Is it when you have taken the initial 1003 by phone or email, or is it when you have a signed 1003 by customer and have verified income and assets, etc?
02/08/2010
In business credit, Regulation B states oral notification needs to be documented; what does this mean and entail?
01/25/2010
On a secondary residence, do you have to give an ARM Disclosure if the rate is adjustable?
10/19/2009
Do newspaper advertisements for IRA accounts require any more disclosures than a CD advertisement?
10/19/2009
If a business client has a business money market account that is restricted to six debits per month (as defined in Reg D), do fees that the business client pays for merchant credit card processing count towards one of the six allowable debits per month? If not, what wording in Reg D can I refer to prove my case?
10/12/2009
Am I correct in stating that the TIL must now be given early and there is not an additional one required unless APR becomes inaccurate?
10/12/2009
Is a financial institution required to pay interest on certificates of deposit or can they pay and disclose 0%?
09/07/2009
Our bank routinely pulls credit bureau reports for all new loan requests. Although credit scores are only one of the criteria used to make a decision on a loan request, a poor score would weigh heavily on a credit decision. With regard to the FACTA provision of providing Credit Score Disclosures to residential mortgage loan applicants, a question arises about those applicants whose credit bureau we request and the report is returned without a credit score. The lack of a score is sometimes a factor in determining the decisioning of an application, the need for a co-signer, or even the interest rate that may be charged. Should a customer with a credit bureau history, but no score, be supplied with the notice?
09/07/2009
We want to start charging our customers for credit reports and flood determinations. Is it ok to only charge customers that we actually close the loan with or would this be discriminatory? We don't want to charge the credit report fee at application. We would rather wait until the loan is closed before the fee is imposed on the customer, therefore if a denial is made, the denied customers would not have the fee imposed on them.
07/13/2009
Is a holding company officer considered an insider under Reg O?
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