A renowned regulatory compliance authority, Randy is a Compliance Specialist with ppdocs.com, powered by PeirsonPatterson, LLP.
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.
You can reach Randy via email at: careyrandy@comcast.net
12/01/2024
If we have a business customer that notified us that a check cashed against their account was "altered" and that check was determined to be a counterfeit, but the signature on the check reasonably matches the signature of the authorized signer (almost exactly), would we still be liable to credit our customer for the counterfeited check?
11/24/2024
If we feel that a debit card holder may be heading towards becoming a collections account due to excessive state lottery and state liquor store transactions on a daily basis, can we restrict the card from being used at those MCC transaction types?
11/24/2024
Our marketing department brought up the idea of handing out $50 coupons to our customers to entice them to refer folks to get a mortgage loan with the bank. The idea is that if a customer refers someone for a mortgage loan and it closes, the customer can redeem the $50 coupon for cash. I reviewed 1026.36 but it only seems to cover MLO compensation. RESPA's 1024.14(b) seems most applicable but i'm not sure if that just pertains to the parties involved in the transaction. This would be a referral for our customer who told someone to get a mortgage with us. Are there any regulations on a $50 referral ‘bonus/compensation’ to our customer for referring someone to one of our MLO’s to close a mortgage? It seems similar to what the big banks do with something like a $200 bonus to open an account with them.
11/24/2024
Can you remove the primary borrower off a pending loan? I was under the impression that as long as both borrowers were married, and they both completed the application and received the initial disclosures that the primary borrower could be removed and the co-borrower moved over to the primary borrower position. This was the only way, and any other attempt would result in a denial, or withdrawn application. We have done this with a couple of our loans, but upper management wanted documentation stating that this can be done.
11/24/2024
When securing a loan with an assignment of leases and rents, how much could be advanced compared to value of the lease assignment? Is there any "standard" which is acceptable?
11/17/2024
We have been notified by Mastercard of a data breach and need to inform our customers who were impacted by this incident. In previous financial institutions where I have worked, we typically send a letter to notify customers about the card compromise. This letter includes the date we will be closing their card and informs them that a new card will be issued. My question is regarding the regulations surrounding this process: Can customers choose to keep their card active? If so, where does the liability lie if they experience fraud in the future? I am looking for a regulation or a Mastercard rule to implement a formal policy, as there isn't one currently in place at my current financial institution.
11/17/2024
If we have a consumer HELOC denial with the stated purpose of "purchase land to build a gas station," is it HMDA reportable?
11/17/2024
When banking an insurance agency that handles only cash deposits, what documents are required? Do we have to obtain their contract agreement, if they are a sole proprietorship and are licensed with multiple agencies? I am located in Georgia and regulated by the OCC.
11/17/2024
What types of accounts does a financial institution need prior authorization for from a client before running Chexsystems? How does a financial institution have to notify a client that they are going to run Chexsystems? Regarding business clients - we run biz Chexsystems on the business and the beneficial owner, correct? How do we have to notify them that we are pulling their credit to determine if we can open a new account?
11/10/2024
How can a HELOC be reopened when closed erroneously without the member having to reapply for financing?