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:
Are there regulations or risk issues allowing customers to prepay consumer loans? I know that there is a risk of extecsions for installment loans, but need to know how many months in advance a customer can prepay installments rather than adding excess payment amount to principal?
Regarding NMLS: We have an employee who came to us already registered with an NMLS number which we transferred to our bank. The intent was to have her work her way into a lending position after sufficient training. Her role has changed and she is no longer going to be a possible MLO.
Since she is NOT in an MLO position but still has a number, is it required we include it on all of her correspondence, business card, etc. when she is not serving in this capacity? We may consider not renewing her NMLS at some point but she is renewed through 2021.
Where can I find the retention requirements of various bank records on how many years we need to save them?
I am new to work in a bank and want to know if all banks verify the cashier's check the same way. If a non-customer walks into the bank and tries to cash a $180K cashier's check and asks for $5000 in cash and the remainder in a cashier's check, do I legally have to do this? And if they don't want to open an account do I have to cash it for them?
How do we know when a check is valid, or if it has been altered or when it isn't as I haven't been taught how to verify another bank's cashier check?
If a client withdrawals over $10K from an ATM machine over the weekend, Saturday and Sunday are we required to file a CTR on our client?
Our borrower applied with the occupancy type shown as a second home. Underwriting determined the occupancy type is an investment home. The loan was denied due to insufficient collateral based on the property type as an investment home and not a second home. Should we report on the HMDA LAR as a second home or an investment property?
Regulation E states the investigation of a dispute must be completed within 10 business days if written notice is given, but can take as long as 45 days if oral notice is given. If a customer calls the bank to report a disputed charge on their account related to their debit card on a Monday, comes in person to sign the dispute affidavit on Wednesday in order to receive provisional credit, is the investigation to be completed 45 calendar days from Monday or 10 business days from Wednesday?
Our local Chamber of Commerce is giving away raffle tickets for a chance to win a shopping spree downtown for the holidays. They have asked the bank to offer tickets to our customers. My question is, may we offer multiple tickets to customers if they were to sign up for certain services? For example: Make a deposit worth 1 ticket, sign up for online banking and receive 2. Another example would be to apply for a car loan and receive 1 ticket, qualify and finance with us pays 5 tickets.
We have a customer that deposited a check, which we believe to be possibly fraudulent. The check was issued for work in another country and the description doesn't match what the depositor does or the work in the other country. The work is being performed by his girlfriend and we believe the girlfriend is solely on the internet. So there are a number of red flags.
How long does the issuing bank have to return the check to us for reimbursement from our customer's account? Does that time frame differ if the check is deemed to be fraudulent? I have heard up to one year. However, we can't hold the funds that long, or is there a stipulation-reason we could use to hold funds for one year?
If the funds are gone, are we required to return the funds after 90 days? After one year?
We are trying to plan not to get caught having to return $10,000 that we believe to be fraudulent.
We have a client who owns several business accounts under a corporate DBA. The accounts are titled "ABC Corporation, DBA DEF Company". He also has the Family Trust listed under each account. We are told that he cannot have business accounts under the trust because once a trust, always trust. Will he then need to close and reopen these under the Corporation?