Re-perfecting a UCC Lien
03/26/2023
When a UCC is terminated, then the following year it is continued, then continued a second time, is that a valid perfection?
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
Notice at Closing of Required Insurance
03/26/2023
Is it required to have a separate "Agreement to Provide Insurance" form signed for non-real estate secured loans? We are in Tennessee and currently have a section in the Security Agreement that prints with the Note which states the borrower agrees to keep the property insured and if they fail to provide insurance, then the bank may place insurance on the property (Creditor-Placed Insurance Notice) and pass that cost to the borrower.
Unpaid Board Members and Reg O
03/19/2023
We have a board member who sits on the board of a condominium association, but does not receive any compensation to do so by the association. Would making a loan to the condominium association be considered a conflict of interest/Reg O violation? We are thinking not since they are serving on the condo association as a resident (condo owner) in the complex.
Are bank statements required?
03/12/2023
I am looking for clarification on deposit account statements that must be provided for checking or savings account activity, both consumer and business. Reg DD does not require a periodic statement for consumer, but Reg E does, monthly if there is Reg E activity and quarterly if not. What about business accounts since neither Reg pertains to those? If not a requirement, is it a best practice?
Participation and LIFO Loans
03/12/2023
Participation and LIFO Loans
Incentive for Loan Auto-Pay
03/12/2023
Instead of offering a preferred rate (discount) when auto-payments are set up for a loan, we want to offer instead a discount on doc fee charges. Is there any regulation/issue that would prohibit us from doing this?
Specificity of CD Beneficiary
03/05/2023
For a Certificate of Deposit account, can the beneficiary on the account be titled as "Assigns'" in lieu of a specific named beneficiary?
Privacy Policy Update Requirement
03/05/2023
Google is requiring us to add a Mobile Privacy Disclosure to our Privacy Policy. The changes go into effect March 1, 2023. How long before the change goes into effect does the customer have to receive the updated notice? I would think 30 days, but I can't find that anywhere.
Are banks obligated to cross-file with states
03/05/2023
Is there a requirement for financial institutions to file 1099 tax forms (A,B,C,INT,MISC,NEC) with various states or is just the IRS?
Lender Can't Fund - UDAP?
03/05/2023
If a lender has a borrower sign loan documents but has some liquidity issues that extend the funding beyond the rescission period, would that be a UDAP violation? In this example, say the lender expected liquidity to come in from a trade before the rescission was up on the loan. However it was held up for a week. The loan will fund, but a week late. The property is in California if that matters.
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