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
02/11/2024
We have backing lines attached to our Letters of Credit. Most of our backing lines are secured however, the letters of credit are unsecured. We have been told by our core vendor we must attach a backing line. Questions is, do we report the backing lines that are secured based on the collateral when reporting the call report code or do we report in 4A with the Letter of Credit that is unsecured? We haven't found any definitive answers but we want to make sure we are reporting correctly.
02/04/2024
Do business transactions apply to ESIGN - Electronic Signatures in Global and National Commerce Act?
02/04/2024
Are banks held accountable when customers transfer money from HSA accounts to personal accounts or LLC accounts?
01/28/2024
We have a customer that is an agent for one of the local insurance companies. She wants to open an account in her name only using the insurance company EIN, can we do that?
01/28/2024
We have a business customer whose deposit runners are refusing to provide their information for us to collect as conductors of cash transactions. These are typically smaller transactions, but we require a conductors information on all cash transactions over $1,000 for aggregation reporting purposes. They previously banked at a larger regional bank which did not require these runners to provide identifying information. Are we OK to make an exception for this business client unless it is a CTR reportable transaction?
01/28/2024
When a customer has joint account and only one person on the account wants to add a beneficiary to the account, can this be done or must each accountholder agree?
01/21/2024
We recently inquired if we could use self-deposit investments where the bank is acting as Trustee. We have received a legal opinion stating that we can use self-deposit investments so long as we document our due diligence, the trust allows for the investment, and our Money Market Account (MMA) is a competitive rate.
We are currently discussing a referral incentive program which would include our Trust Division. I have read a lot of guidance between FDIC, OCC, and FRB, but I am not seeing anything that speaks to my particular situation.
Can a Trust Officer use a self-deposit investment as Trustee and still receive a referral incentive for this transaction? I personally feel like this is a conflict of interest and somewhat, self-dealing. However, I am not seeing anything stating this would be an issue per se. I am only running into nonretail deposit and broker/dealer requirements.
I have also looked through Arkansas code (our state) and I could not see anything that spoke on this particular situation.
If you have any insight or could point me in the right direction to help confirm or rebuttal my though process, I would really appreciate it!
01/14/2024
I am working with a new core system and we are discussing our exceptions process for items presented that cannot post for various reasons i.e. NSF, closed account, account restriction, etc. This system will not backdate the item to the date of presentment in cases where we choose to pay it. Is there anything that states the item must be "paid" on the date of presentment?
Every other core I have ever used in my 28+ years has always backdated the item to the presentment date.
01/14/2024
Is a check payable "FOR" someone the same as a Representatives Payee? I've seen checks that do not have "Representative Payee for..." just "For..."
John Doe
FOR Sally Doe
Is this sufficient, or what should it read?
01/07/2024
Is the any regulation that prohibits a credit union member from paying their mortgage ahead by a specific number of months?
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