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
02/25/2008
Does the bank need to report the interest earned on an account of a foreign individual with a SSN not valid for employment? Does it need to report the interest earned on an account of a foreign individual with a SSN valid for work only with DHS authorization? Does it need to report interest earned on an account of a foreign individual with ITIN?
02/18/2008
Why did Congress enact the Bank Protection Act of 1968? What was the original reason or event that caused them to write this legislation?
02/18/2008
If a customer deposits $8,000 cash into his or her personal account and $3,000 cash into a business account for which he or she is an authorized signer, does a CTR need to be filled out? What if the customer makes the $8,000 deposit into his or her personal account and one of the other authorized signers on the business account makes the $3,000 deposit, then does a CTR need to be filled out?
02/18/2008
This may seem like an odd question, but can we be required to shovel snow in the winter? My boss at the bank has informed us that he or she has hired someone to shovel, should we have more than two inches of snow, in the morning only. If we have less than that and throughout the course of the day, he or she has provided us with weekly rotating schedule in which each of us would be responsible for this duty. None of us are too keen on this idea. Is there legally something that could restrict this activity or do we just attribute it to the joys of a small business and deal with it?
02/18/2008
If our bank offers special bonus CD rates to customers who are part of a special plan (based on combined account balances), what is the best way to advertise rates? We specify balance to open the CD, but do we also need to give plan specifics that would make one eligible for the bonus rates? I am asking in reference to advertisements and rate sheets.
02/18/2008
When advertising a cash incentive to switch an account on a billboard must we say "for details go to our website" or can we just list the website as the "for details go to" is implied?
02/18/2008
Is a demand clause needed for an executive officer's loan taken out prior to that employee becoming an executive officer?
02/18/2008
Is it required to have a full URAR appraisal done on residential real estate deals exceeding $250,000? Can the bank choose to do a drive-by appraisal instead?
02/18/2008
For funding on warehouse lines of credit should the bank require a copy of the buyer's signed note, copy of the D/T and a title commitment to ensure first lien position?
02/18/2008
If a review appraisal is completed by the same appraiser who did the original, is this a violation of FIRREA? Does the review appraisal have to be from a different apprasier?
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