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
08/20/2023
I submitted an Altered Check Claim to JPM Chase. The bank came back and denied the claim stating the check is a forgery. This is not a forgery. The signature on the checks matches all the others check paid on this account and the signature on the Affidavit submitted for the altered check. The payee and the amounts were altered. I am not sure what my next steps are to recover the funds. What are the avenues other banks have successfully used?
08/20/2023
We had a customer who was attempting to purchase tickets through ticketmaster using their debit card. They were redirected to a different site and proceeded to enter their card information to complete the purchase.
The customer then received a text message of a possible fraud transaction, which was for the dollar amount ($612) that she had just tried to purchase, so she confirmed that the transaction was legitimate. She looked at her transactions moments later and realized that the merchant name for the transaction was not ticketmaster.
She called us the same day and said this may be fraud. She admitted that she was redirected during her purchase. The merchant name is a bitcoin company (transak.com) and we do not have any charge-back rights.
We are wanting to know if we have to take the loss or if we can put the responsibility on the customer since she entered her information in the website and she initially said the transaction was legit? Can you please advise on this?
08/13/2023
Does using purchase price vs actual appraisal amount include commercial or land properties or is that only for consumer dwellings?
Example: purchase price of CML bldg $85,000, appraisal amount $150,000 - based on the supervisory LTV limits, can I lend 85% of the $85k or $150K and not have an exception to the supervisory limits?
08/13/2023
If a credit union allows a member to establish a new transaction account after they pay back the amount owed from a closed, charged off account, would the newly established account be subject to Reg CC's new account definition? This would mean applicable checks deposited into that account to would be subject to new account holds.
Could we determine that the member's actions causing the the charge-off means they forfeit the benefit of the previous account for Reg CC, and this newly opened account would be a "new account" holds under Reg CC, or would this be a misapplication of Reg CC's new account exception?
08/13/2023
Is it legal to print a check on white stock vs. bank stock? What are requirements to be legal?
08/13/2023
If we provide Reg DD disclosure data such as the APY on business account periodic statements, would that require us to follow the other Reg DD requirements such as providing subsequent disclosure notices if we change an account service charge? Our host system is tying accounts together based on Social Security Numbers and Reg DD is triggered by the CIF and not by the individual accounts.
08/13/2023
Are there any regulatory requirements for an FDIC insured bank to publish it's phone number in the yellow pages or any other publicly available phone directory?
08/06/2023
We have a loan for an apartment building with 21 efficiency apartments that has been moved into a flood zone. The entire building is not in a flood zone, only a few of the efficiency apartments are. Can the flood insurance be based on only those apartments rather than have coverage for the entire building?
08/06/2023
We had a customer call to list two people as PODs on his account. He had recently been diagnosed with stage 4 cancer. We printed all new forms for him to come in and sign. We confirmed this customer when he called. He passed away before he could sign. Can we honor the customers wishes if we put "as per verified telephone call" and show the date of the call?
08/06/2023
Can we still charge a fee for excess money market transactions even though Federal Reserve eliminated the 6 per month transaction limit?
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