Commercial Loan Modifications
05/15/2022
Do you need to modify or prepare a change in terms on a commercial loan when lowering the interest rate but not changing the maturity date? Can it just be done with a maintenance request?
Randy Carey
Bio:
Randy Carey is a Compliance Specialist with PPDocs.com. A leader in technology, PeirsonPatterson, LLP (PPDocs) has enabled clients the ability to order, produce, deliver, print, and track closing document packages through the use of their website, www.ppdocs.com. PeirsonPatterson takes pride in its reputation of providing personal attention to their clients, regardless of their size.
Previously, Randy spent 15 years as an independent regulatory compliance and bank management consultant. He also has 20 years of banking experience which included positions ranging from Check Sorter Operator, Proof Supervisor, Senior Training Officer, Staffing Analysis Officer, VP and Project Manager, National Retail Loan Payment Processing Manager, VP - Compliance and Community Reinvestment Act Activities, and VP and Director of Internal Audit.
He is a graduate of the ABA National Compliance School, the ABA National Graduate Compliance School, and the ABA National Truth-in-Lending School. He has served as an instructor for the American Institute of Banking, the Texas and Oregon Bankers Compliance Schools, and the BankersOnline BSA Top Gun and Lending Triage Conferences and passed the Certified Bank Compliance Officer examination. He is also a former member of the Community Reinvestment Leadership Council of the Federal Reserve Bank of San Francisco.
Previously, Randy spent 15 years as an independent regulatory compliance and bank management consultant. He also has 20 years of banking experience which included positions ranging from Check Sorter Operator, Proof Supervisor, Senior Training Officer, Staffing Analysis Officer, VP and Project Manager, National Retail Loan Payment Processing Manager, VP - Compliance and Community Reinvestment Act Activities, and VP and Director of Internal Audit.
He is a graduate of the ABA National Compliance School, the ABA National Graduate Compliance School, and the ABA National Truth-in-Lending School. He has served as an instructor for the American Institute of Banking, the Texas and Oregon Bankers Compliance Schools, and the BankersOnline BSA Top Gun and Lending Triage Conferences and passed the Certified Bank Compliance Officer examination. He is also a former member of the Community Reinvestment Leadership Council of the Federal Reserve Bank of San Francisco.
Areas of Expertise:
AML/BSA Compliance
Deposit Compliance
Lending Compliance
Conference Speaker
Contact info:
You can reach Randy via email at: careyrandy@comcast.net
Questions Answered
Are ARM Disclosures Needed
05/08/2022
As an independent mortgage banker disclosing an Adjustable Rate Mortgage, is it necessary to provide the consumer an ARM disclosure or are we covered by disclosing the Loan Estimate and Closing Disclosure which provide ARM details?
Survey with a Drawing
05/08/2022
Can we email our online customers with a survey and entice their opinions with a drawing (4 winners will receive $250)? Only customers are contacted but only our online customers have opinions on our online banking. Can we do this activity or does it fall under "lottery" prohibitions?
Business loan denied because of Owner's Report
05/01/2022
We have a business entity request for commercial credit and a credit report was pulled on the two owners, with the credit request denied based on one owner's credit score. If the FCRA portion of the Adverse Action Notice is completed is that wrong? If this is included and the score, key factors etc. are for the credit score used in making the credit decision is sent to both owners, in the name of the business entity, is that wrong?
SOP, adding a person to a deposit account
05/01/2022
How can I add someone to a deposit account? Is there a specific procedure for the signature cards or disclosures if they're even needed?
NSF Fees on Loan Payments
05/01/2022
If we charge a $25 return check fee for dishonored loan payments, is this charged to the principal balance or like a late fee that doesn't effect the balance? This charge is disclosed to the borrower.
Regs on Holding Statements
04/24/2022
What is the regulation and where do I find this, on holding bank statements for customers, or is it a bank policy issue?
Signers on Parnership Loan
04/24/2022
If I am doing a loan for an LLC where two partners own 40% each and the third owns 20%, do I need any information/documentation on the third owner if he is not going to be a borrower on this loan? Would meeting minutes be required where it is decided the third owner will not be signing the loan?
Is Reg O Reporting Charter Driven?
04/17/2022
Are state-chartered, non-FRB member banks subject to the reporting requirements of Reg O as relates to identifying related interests and the required annual report to the board of the outstanding amount of any credit that is secured by shares of the institution if the shares of the institution are not publicly traded?
Fees Disclosed in Free Accounts
04/17/2022
I am reviewing a deposit ad for branch flyers. The Free Banking Service package includes an array of free services including free money orders, official checks, and stop payments. Should there be a disclosure as to how many and how often the customer can receive this benefit or does the statement to contact an employee for more information cover this?
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