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:
All of our TRID loans are on a variable rate that changes monthly. I thought the required rate cap was an increase or decrease of 2% each time it changes. Now I cannot find any documentation regarding this issue. I know we have to disclose the ceiling but is the adjustment under our discretion?
Is it true that the NFIP will only pay out if the borrower has hazard insurance in place on the property? Our bank's practice is to get hazard insurance at closing, but doesn't monitor for it after that. If the hazard insurance policy has expired and there is a flood, will the NFIP pay out?
Some taverns/bars are involved in "Sporting Pools" aka: Football Pools, Office Pools, Super Bowl Pools, etc.
Does FinCEN encourage SARs to be reported for a business involved in such activity? Gambling is not legal in my area.
If a credit union board holds a board only meeting after the normal Board meeting, must the Board Chair prepare special minutes or can they provide notes to add to the regular Board meeting minutes?
I understand the Joint Overdraft Guidance states that overdrawn accounts should be charged off after 60 days. Is there anything that would allow for an extension past the 60 day mark? (i.e. a fraud investigation, pending transactions, approval from upper management, etc.)
I have recently learned about a rather unique construction perm product and
have a question about it in regard to the new upcoming TRID rules. Here's
how the product functions now. The loan is a one-time close, 30-year term,
fully amortizing from the beginning. Only one LE/CD is issued. The rate is
fixed at opening and does not change at all during the term. There is no
interest-only period. At closing, the funds are put into an escrow/reserve
account and disbursed to the borrower periodically over the construction
period. At this time they do not charge any inspection fees but are
considering changing their process to have the inspections conducted by a
third party and charging for three inspections.
If these fees are disclosed to be collected at consummation, what recourse is
there if an event occurs that requires an additional inspection? Does the
bank simply have to absorb that cost since this is a zero tolerance cost and
the CD has already been issued and compared to the LE?
If these fees are to be collected after consummation, disclosed on a separate
addendum, and this event requiring the additional inspection occurs, can the
bank simply collect the additional fee without violating the zero tolerance?
When a corporation has an account titled "Smith mowing DBA Jones Hardware," may we accept deposits in both company names into the one
Currently, we provide our borrowers with a coupon book for auto and personal loans. Are we required to provide an error resolution notice with these?
Can you place a Reg CC hold on a Savings Bond?
We are on the verge of implementing eSign for our branches for maintenance tasks in addition to account opening and lending. I think this will help with some customers who tend to change signers rather frequently, such as with closers on settlement agents' accounts. I'm beginning to consider whether collecting their signatures on Resolutions adds value, or whether an authorization from the principals in the Resolution is sufficient? I am also considering whether we can use a separate authorized signer list with signatures as an appendix, rather than re-creating a signature card every time there is a signer added or deleted. Am I behind the times?