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 are opening a new branch and we will be sending out invitations/brochures inviting people to check out our new branch at the grand opening. We aren’t asking anyone to open an account or apply for a loan on the brochure. Is this invitation/brochure considered an advertisement and if so, what disclosures would apply?
A local credit union is having a drawing for new member accounts. I know that banks are prohibited from offering lotteries/sweepstakes, but are the rules the same for credit unions?
Is it appropriate for a bank to ask a customer what age group are you in and what age do you plan on retiring?
Do we need to keep a copy of the Federal Credit Application Insurance Disclosure in our files when an adverse action notice is sent to a customer for a consumer loan?
When should pandemic supplies be purchased?
Do you recommend the hiring of a consultant for the creation of a pandemic policy?
How do you get Senior Management to buy into the serious need for business continuity planning, including the need to spend money for adequate back-up materials, filters, etc.? We recently were hit with a computer virus and were without internet for 4 days. We should have a back up method for that!
How often should we update our disaster plan?
When granting open-end credit card accounts is it necessary for the bank to call the applicant (if the phone number is provided in the bureau statement) in the event that they have an extended fraud alert on their bureau or can the bank leave a message and accept a return call from the applicant and verify the applicant's bureau contact phone number from the bank's caller ID? Does the bank have to call the bureau contact number of a card holder (with an extended fraud alert on the bureau) who requests a credit line increase or to have an account reactivated and new plastic sent or are these two scenarios exempt from FACTA verification compliance?
One of our bank officers is retiring. The branch would like to send out a postcard to her client list inviting them into the bank on her celebration day to say goodbye and have cake. Do we have any privacy issues in doing this since it will be a postcard?