Appraisal Fee Disclosure
02/26/2007
If a customer pays the appraisal fee prior to closing should that fee disclosed as a POC and does it affect TIL?
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.
02/26/2007
If a customer pays the appraisal fee prior to closing should that fee disclosed as a POC and does it affect TIL?
02/19/2007
I need some advice regarding Reg D. Our bank would like to offer our business customers a checking account that could sweep excess funds into another account nightly in order to earn interest. Our competition is offering an "Automated Funds Manager Account" where they sweep funds into an investment fund, such as repurchase agreements. How can we offer our business customers a checking account that would offer a "sweep" feature and avoid the six transfer limitation? Do we have to sweep funds into outside investment accounts or can we sweep into one of our internal products?
02/19/2007
Do you have the HMDA Definitions of Ethnicity? (How to define if a person is White, Asian, etc.)
02/19/2007
Can we require verification of medical disability as a condition of the loan approval process?