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
02/04/2008
Is the amount of hazard insurance that should be required on a real estate secured loan calculated as the appraised value less land value or loan amount less land value? Does it differ according to property type?
02/04/2008
We have a joint account where the primary owner is a U.S. resident with valid TIN and the secondary owner is a non-resident alien with an expired W-8BEN. Should we apply backup withholding to this joint account?
02/04/2008
We are a state chartered de novo bank (MD), but expect to have customer accounts and to transact branchless banking in other states. What are the requirements to do so (e.g., business license)?
01/28/2008
If a bank withdraws more than $10,000 in cash through a GL account to give employees monetary gifts, does this require a CTR for the bank? The bank has not filed a Designation of Exempt Person on itself.
01/28/2008
How do you report joint owners on an organization account which is exempt from federal income tax under section 501(c)(3) on a CTR which was filed for a deposit of greater than $10,000?
01/28/2008
Can banks take copies of credit cards for CIP documentation when opening a new account? I thought this was against regulation? Can you please refer me to written verification?
01/28/2008
Is it acceptable for a payroll check to be signed in the name of the entity? The checks are paid by XYZ business and are signed "XYZ" on the signature line instead of an authorized person signing their name. We have a situation where some of our customer's payroll checks are signed with the entities name. The business does not bank with us. Should we be concerned? Does this practice create some risk to the entity should they ever have to dispute an item? How do they prove that an authorized person signed the checks?
01/28/2008
Is there a requirement to return participant paid loan documents for 401(k) plans to the borrower?
01/28/2008
We originate single family mortgage loans and sell them in the secondary market. We do not charge a tax service because we do not keep the loan to service. When the investor buys our loan, they charge us a tax service fee. My compliance department believes I should have to show the tax service fee as POC by the borrower. I contend that the tax service fee is part of the fees involved with the sale and part of our net compensation, therefore is exempt from any RESPA disclosure. What is the answer?
01/28/2008
Should a bank use a timeshare as collateral on a loan and would you record a regular mortgage?
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