Bio:
Patti founded Financial Solutions in 1990 to provide community financial institutions with an effective solution for the ever increasing need for cost-effective regulatory risk management. The company continues to be a very fulfilling entrepreneurial adventure for Patti and her husband, Gary Blenden. Patti brings to her clients over 35 years of banking experience. She worked her way through college in banking and after graduating from Louisiana Tech University with a B.S. in Accounting, she returned to banking after a couple of years in communications. Patti is a firm believer that community banking is determined far more by your heart and spirit than by asset size! She is a Certified Public Accountant (CPA) and a Certified Regulatory Compliance Manager (CRCM).
Patti’s love of people and thorough understanding of the current regulatory environment provides a remarkable ability to integrate, streamline and automate related priorities without compromising compliance, performance or your sanity! She is a dynamic speaker and leader with strong, intuitive management skills. Highly acclaimed as an effective as well as entertaining compliance instructor and motivational speaker, Patti is frequently a featured speaker at national and state compliance seminars, schools and conferences as well as a frequently published compliance author. She also serves as Associate Editor of the ComplianceAction Newsletter, Lucy Griffin’s highly respected long-running compliance resource.
Areas of Expertise:
Compliance Action Newsletter
Questions Answered
05/30/2016
We have an application that started as an $18,000 home equity line of credit (HELOC) for home improvements. The bank counteroffered the applicant a closed end mortgage in the amount of $8,671 and they accepted that offer and their government monitoring information was then collected and disclosures were sent. Days later the applicants called back and stated after further consideration they were not comfortable with doing the closed end mortgage, which raises a couple questions: 1 – do we go back to the original request of a HELOC and deny the HELOC application for excessive LTV listing our counteroffer; or 2 – do we report the accepted closed end mortgage counteroffer as home improvements on our HMDA LAR as a withdrawn request?
05/22/2016
I have a question concerning the Rate Lock disclosure on the Loan Estimate. If we disclose “NO” for the Rate Lock and don’t set the rate until the Closing Disclosure is provided do we have to provide a Revised Loan Estimate before the loan closing? What if the interest rate does not change from the Loan Estimate to the Closing Disclosure?
05/16/2016
In the last Compliance Action, there was a Rate Lock disclosure Q&A. My concern is not about the meat of the question, but about a comment regarding written rate lock agreements. It stated that the rate lock must be “written” to officially lock the rate per the TRID. I cannot find where TRID says that the rate lock must be written. Can you please point me to the section or other documentation requiring written rate locks? We are internally debating the discrepancy between TRID disclosures and the HOEPA/HCML issues related to setting the final rates.
05/01/2016
What are lenders doing when an appraisal comes in low, and a counter-offer is made to the customer? Since we are mandated to issue a new LoanEstimate within 3 days; it’s a challenge for our loan officers to get their customers to decide in 3 days whether they want to proceed with an option such as PMI, secondary financing, lower amount etc.How are other lenders handling this?
04/25/2016
One of our lenders asked if he is able to provide yard signs to his realtor contacts to place on their listed properties for sale. I think it is a great marketing idea. The sign would state something to the effect of “Financing Available through “XYZ Bank” for qualified applicants. Please contact [loan officer name and phone number] or stop in at our ABC location to complete an application.”
