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.
Areas of Expertise:
AML/BSA Compliance
Deposit Compliance
Lending Compliance
Conference Speaker
Questions Answered
02/16/2020
Should non-RE loans that exceed the dollar threshold for Regulation Z coverage still be considered consumer loans as far as coding and reporting?
We have a difference of opinion. One side believes the Reg Z exemption essentially changes the loan into a commercial loan in every way. The other thinks that the disclosures in the documentation is where the exemption is primarily seen and the loan should be coded and reported exactly like any other loan of its type that is under the threshold. Any clarification would be appreciated.
02/16/2020
If TILA disclosures are provided in a loan to a business entity and the APR is understated - is this a violation of regulation Z although loans to business entities are exempt from the coverage of Regulation Z?
02/16/2020
Is the servicing disclosure required on Home Equity Lines of Credit?
02/16/2020
If a HMDA applicable application was withdrawn by the borrower before it ever got to the originator, what do we put for the NMLS number? Can we leave blank, should we put N/A (I believe that's only for Originators that don't have and don't need NMLS numbers), should we default to a manager or is there another recommendation?
02/09/2020
I just found a hoard of FDIC Quarterly Banking Profile books. I am assuming that we have kept these over the years because no one knew how long to keep them. As a rule of thumb, I have been keeping things that I am unsure of for at least 5 years. I have not found something in my department that has to be kept any longer tan that. I could not find any record retention guidance for this book. Should I trust my gut and just keep 5 years worth?
02/09/2020
Can a lender accept verbal telephone confirmation from an applicant of receipt of the 3-day closing disclosure?
02/02/2020
We have an IRA beneficiary who has inherited an IRA. She is a non-spouse beneficiary of the original IRA, and has named her spouse and daughter as beneficiaries of her inherited IRA (payout account). When calculating FDIC insurance, what ownership category applies to this inherited IRA, is it considered a "certain retirement account" or a revocable trust account?
02/02/2020
We have a credit transaction that came in today on a closed debit card. This card has been closed for so long that it is not on our system any
longer. This was presented as a "force post" transaction and did not go thru the authorization channel. Can we return this transaction even though
it is attached to a debit card?
02/02/2020
Can a home health nurse legally add themselves to an elderly person's account?
02/02/2020
We received notice on Oct. 28 that a borrower was now in flood zone AE. A 45 day notice was sent (force placement would have occurred on Dec. 13). On
Dec. 12 we received a copy of a declaration page showing coverage starting effective Jan. 12. I believe we need to force place and then cancel on Jan.
12 at the borrower's expense however I'm getting push back because of a claim of evidence of insurance (again, the policy is not effective until
Jan. 12). The declaration page shows payment in full however we do not have an application nor proof of payment. Do we need to force place this interim
period?
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