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:
The question I have is in regard to CIP. For a new account you have to obtain identification such as drivers license w/photo. But can you accept a major credit card? I thought I understood that some states prohibit the use of a credit card for identification. What states prohibit this?
If a loan customer (either business or consumer) lists income on the application or financial statements that does not agree with submitted tax returns, does this trigger the need for us to file a SAR on the business/consumer?
Our bank is considering a "club account" marketed towards young professionals. I know on the lending side we have ECOA and fair lending to take into consideration, what areas of potential discrimination should we consider on the deposit side? I have read the question answered by Andy Zavoina entitled Is Free Checking for 50 and older an ECOA violation? Are there other regulatory areas to take into consideration?
Can our Lending department use a credit report from our mortgage department to offer a pre-approval Home Equity to a customer? Is there a section in the FACT Act that addresses this and can you refer me?
Does Reg O apply to guarantors, co-signers, and grantors - or just to borrowers?
Are there any new laws out prohibiting banks from issuing debit cards on business accounts?
What is the time frame allowed to return a cashier’s check to BOFD for NSF or fraud?
I recently noted in an audit report that the bank has no policy that prohibits cash exchanges between tellers. Management's response was, since there is very little risk involved no policy is needed. What's your opinion?
Are we still permitted to film a customer's drivers license a part of our CIP policy and is it required by the Patriot Act?
We would like to offer an overdraft protection product for our commercial accounts. What compliance issues will be involved? We have a consumer product already with the proper disclosures.