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
We offer business credit cards through a third party vendor. The bank currently approves the applications and handles disputes. We are now going with a company that approves the applications and handles all disputes. This company bought all the consumer cards, but did not purchase the business ones. We want to send a letter to the business customers and let them know we are no longer offering business credit cards and within 60 days the cards will no longer be active. Are we in violation of Reg E or Z by doing this?
I understand per the Interagency Statement on Retail Sales of NDIP that the referral fee may be a one-time nominal fee paid to the bank employee by either the insurance agency or the bank. If we structure a referral fee so that the first three referrals do not warrant a referral fee and starting with the fourth referral the bank employee receives a fixed amount nominal fee per referral retro-active to the first referral made. Would this be acceptable as a one-time fee?
I operate the mortgage department for a bank. For years we have referenced an article on your website entitled <a href="http://www.bankersonline.com/compliance/gurus_cmp0507h.html">"RESPA Fee Checklist"</a> to determine if we can pay a referral fee on mortgages referred to us by other mortgage companies. We were recently advised by an FHA representative that we could not pay a referral fee to any mortgage company if that mortgage company is not licensed to originate FHA loans, regardless of the work that they may have performed. Are there any other updates to this rule that we need to know about to ensure compliance?
We have a customer who wants to refinance the duplex and she is living in one side and renting the other. Can we refinance the duplex together since one side is a home?
Can a local soccer club have a NOW with interest checking account?
We were keeping a manual log for HMDA at the beginning of the year and now we have to enter the information on the Loan Application Register (LAR) in the HMDA software. Does it matter which order we enter the information?
I was at a seminar presented by Jack Holzknecht regarding implementing the new Identity Theft Red Flag and Address Reconcilement Rules. Do we need to monitor each and every address change or be able to sample a number of them and monitor that way?
We normally take a copy of the driver's license of a new commercial borrower and put in the file for CIP purposes. We are now being told that we need to complete a CIP verification checklist and have that in the file also. Is the checklist necessary and if so, can you direct me to the regulation?
What are the highest risk customers for money laundering and what are the specific red flags for unusual transactions within that customer group?
When should the Red Flag Checklist titled "Maintaining an Account" be used?