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
One of our business customers has his bookkeeper make the deposits even though she is not a signer. She comes to the bank and provides a deposit slip with $57 cash recorded and presents a $100 bill. Should we break the bill and deposit what is on the slip only? If not, how should we handle this?
We have a home loan on our books that is being refinanced with no new money. The original owner of the property and the borrower (who are the same) is now married and the spouse will be signing the new note and mortgage. Will a right of rescission be needed and who would sign it?
I have read the following statement under Reg B staff interpretations of 202.13 (#5) "an application for open-end home equity line of credit is not subject to this section unless it is readily apparent to the creditor when the application is taken that the primary purpose of the line is for the purchase or refinancing of a principal dwelling". To me that means that if an applicant applies for a HELOC with the intention of purchasing or refinancing their home that we (the lender) should gather government monitoring information. Am I understanding correctly? If I am, what is the creditor supposed to be doing with the GMI? For HMDA we report the GMI on the HMDA LAR, but there is not a Reg B LAR to my knowledge.
Can you list the type of transfers subject to the three per month and the six per month transfer limitation according to Reg D?
The HUD Mortgagee Letter 2006-08 states that notice of servicemembers rights must "Be sent to all homeowners who are in default on a residential mortgage." Does this mean notices are to be sent to servicemembers only who are in default or does it require the bank to send notices to all homeowners in default regardless if they are servicemembers or not?
When ordering credit reports for applicants, we have a range of prices from our vendor depending on what is on the report. To simplify collection of this fee, could we charge a flat rate to all applicants? Will this trigger any additional requirements since we may be charging more than the actual cost?
A bank that originates consumer construction loans receives an application from a broker (not exclusive to the bank) as the broker has arranged for the permanent financing. The bank approves the loan for construction that will include purchase of the land/lot. The broker forwarded the application and his early RESPA disclosures to the bank. Is the bank responsible for providing their own RESPA disclosures for the loan they have committed? It seems that the broker's disclosures are only pertinent to his loan.
I am a new compliance officer and in the process of developing a procedure pertaining to ID theft. How do some institutions handle holds on accounts for customers that are a victim of identity theft (FACT ACT)? I know that we could close the deposit account that is affected by the ID theft and reopen a new one, but what about the other deposit accounts the customer has with our institution?
We have a non-RESPA Auto Loan under 25,000.00. The credit file is missing the signed final TIL. Is this a Reg Z violation and should we redisclose?
Is there anyone who has a model/sample disclosure or notice for ATMs and teller windows concerning the access of the Overdraft program and the fees associated with it? Also, when an item is paid using the overdraft protection does the periodic statement have to say "overdraft item paid fee" instead of "NSF paid item fee"? I am not sure that our system can do that.