CRA LAR - Coding Group Homes
11/24/2008
With regard to CRA LAR are group homes considered code 1 or 3? Are they deemed non-farm residential real estate?
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.
You may contact Patricia via email at plcashman@cashmancs.com.
11/24/2008
With regard to CRA LAR are group homes considered code 1 or 3? Are they deemed non-farm residential real estate?
11/21/2008
How frequently should we have a disaster drill?
11/12/2008
Do regulations require a specific pandemic flu "Policy". We are incorporating procedures for avian flu/pandemic in our disaster recovery plan. Is this sufficient?
11/10/2008
Is it a violation if the board adopts a resolution under Reg O and names executive officers, but excludes vice presidents who work and submit policies to the board for approval? Senior management reviews the policies before they are submitted to the board. What constitutes participation in the major policy making function under Reg O?
11/10/2008
We have a loan officer who is an active realtor. The loan officer doesn't submit loans where he is the realtor, but goes through another loan officer. Is this a RESPA issue? His realtor business is a separate business from the bank.
11/03/2008
Is Saturday considered a banking day if only the drive-thru is open?
11/03/2008
I need to know what we need to do to be in compliance with Reg R Section 218.701. Our employees do receive a referral fee for referring a customer to an investor.
10/27/2008
Is it necessary under fair housing to disclose assets/net worth? The question has been raised that we must input all customer asset information on HELOC applications to give an accurate net worth for fair housing. Any lender I have ever worked with has never done this.
10/13/2008
I need a definition of Reg CC case by case holds and exception holds.
09/22/2008
Does the bank have to provide a notice outlining the action taken and/or results of the investigation as Reg E requires on debit card disputes when a customer reports an ACH transaction as unauthorized or disputed?