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:
There are competing thoughts on the appropriate way to treat an application when the Loan Estimate is not provided by the 3rd business day following the applicant's submission of the six pieces of information.
Theory 1 - Cancel the existing application and restart the application process. This may be due to some issues with selling the loan on the secondary market.
Theory 2 - Show it cas a "self-identified" issue on the file and continue with the file as is. As long as it is not a pattern in practice and is just a one-off from the established controls, there should be no ramifications.
Please help in identified whether #1 or #2 (or may be a 3rd option we aren't thinking of) would be the most appropriate.
Our mortgage department is putting together a script for a generic radio ad promoting their department and our offering of home loans. I know the obvious requirement of FDIC and EHL being mentioned. However, I'm unable to find concrete support as to whether our bank's NMLS ID must also be included. I saw a comment in the forum stating that banks aren't required to include it but can't find regulatory guidance to support that. Can you offer me some wisdom or direct me to a resource? I'm in Texas, by the way. I've also searched for state specifications and came up empty.
Can a relationship manager be personally liable for flood damage?
When we have a TRID loan that we have already issued the loan estimate to the borrower, and we find out that the borrower will be paying the seller’s fees at closing. Do we have to include the seller’s fee in with our tolerance calculation since the buyer is paying it?
Let’s say we have state/tax stamps, usually paid by the seller. At closing we find out the buyer is paying the fee. This is a zero tolerance fee, do we have to add it into our tolerance calculation since it is a seller’s fee just being paid by the buyer?
We are trying to update a residential loan policy and our review committee would like to know what would happen if we failed to comply with Fannie Mae QC requirements for prefunding and post-close mortgage loans? I can find info on post-close penalties and requirements, but nothing for not completing prefunding QC.
Can you point me to any penalties, or requirements to self-report and/or buy-back loans if we don't do prefund QC?
In a webinar I attended earlier this year on Levies it stated, “Levy proceeds must not be reduced by any fee charged by the bank for processing the levy.” Would this rule apply to levies at the state level such as from the State Comptroller office or for Child Support?
We are signing a merchant services contract with a third party. They have a service where the bank can share transactional data of customer accounts to determine if the commercial account it utilizing another card processor. I was under the impression that we did not have to disclose to our customers if we were only sharing commercial account info. Am I correct on this?
Have there been any changes to RESPA since 2019?
We don't make owner occupied mortgages, but do make business purpose loans for rental properties. Do we need to continue using the Equal Housing Lender logo in advertising?
Our institution is based in Missouri, but we offer an online savings account. We are wondering about what state laws we use for charging dormant/inactive fees to accounts? Missouri Law is that once an account is inactive/dormant for twelve months we can charge a fee up to $5.00 a month. Then after five years of inactivity, the account is considered abandoned and will need to be sent to the State Unclaimed Property department. If a customer from different states opens accounts online with us, do we abide by Missouri Law or the state law which they reside in?