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.
Areas of Expertise:
A question has come up after we prepared a Note for a commercial loan. It was dated July 15,, but the customer did not return these documents until July 22. We funded this loan and effective dated our loan to the 15th to match the Note. Now management is saying we should not have effective dated the loan, only the date we actually funded it.
Can we do this, not just for commercial but also residential loans? What is the correct way to handle loan docs returned after the Note date?
Are there any specific requirements or restrictions when it comes to lending to a non-US Citizen?
We have a customer who passed away. The customer was the sole owner of two corporations. The first corporation is a real estate holding company. There is a loan and DDA to this entity. The loan payment is auto-debited from the DDA. There is a second DDA to the other entity, also a corporation, which is to the operating company. Can we continue to pull the payments from the DDA to keep the loan current until the estate is settled and the loan paid off?
Can a Home Equity Line of Credit be done for a borrower who has PMI insurance on their first mortgage?
Can you refer me to the guidance for assessing the BSA risk for coin operated amusement machines operated in convenience stores who happen to be
a customer of our community bank?
For banks that provide combined ECOA-FCRA disclosures, is it standard practice to “Check the 1st Box” and provide FCRA credit score information if the decline reason is not based on the consumer report, but some other factor? (i.e. insufficient collateral, product not offered, out of lending area) Do other banks do this?
We understand that we do NOT have to “Check the 1st box” and provide credit score information if it was NOT used in making the adverse decision, but what would be the risk to provide this information in the above cases?
Given all other HMDA reporting criteria being met, would a bungalow colony be considered HMDA reportable?
If the buyer is being charged by the attorney to prepare the purchase contract, would we reflect that in Section C or Section H?
Also, would the fee description have "Title" in front of it?
Reg Z covers individual consumer use for credit cards plus a few sections which are for business use, one of which is for unauthorized use if the
business has been issued 10 or more cards. What is the rule and/or regulatory expectation on how to handle legitimate billing error claims
(i.e., charged the wrong amount) from business card accounts? And, are there common business practices used in this scenario such as something
parallel to the individual consumer rule in TILA, 1026.13?
We received a cash deposit exceeding $10,000 into a deceased person's estate account (personal checking). The executor is an authorized signor on the
account. Will the Benefactor for the transaction be the deceased? Will the executor be listed on the CTR as well? Note- the executor was not the