Bio:
Rebekah is the owner of Elucidate LLC, a compliance training and consulting company. Elucidate means to "make clear, explain, throw light upon", and describes Rebekah's desire to illuminate the complexities of compliance with passion and fun. She's created and produced a TRID music video parody and several Compliance Breakout escape rooms, which she frequently provides at state banking compliance conferences. She is an accomplished speaker and regularly provides webinars through BOL and Compliance Resource.
Rebekah is currently serving as the VP Director of Compliance for a $6 Billion community bank in Montana. She began her career in 1995 at a private lending company, but soon settled into banking, where she's covered nearly all of it - customer service and teller work, loan processing and review, and security and business continuity. She now oversees CRA, BSA and all aspects of compliance as a senior leader. She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams.
Rebekah has a bachelor's degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006.
Questions Answered
03/31/2024
We have a new employee who was registered as an MLO at another financial institution. Upon updating their NMLS registration for our employment, we learned their fingerprints are over 3 years old. Can they still originate loans with us?
03/31/2024
If a customer deposits a check into their account with us, and that check is returned to us as unpaid, may we charge them a fee when we do the chargeback?
03/24/2024
I work in HR, and know that our Executive VP earns a substantial annual bonus. He does not really do any real estate lending, but often says he makes more loan deals on the golf course than anywhere else. I assume this includes home loans. Up to this point, he has kept his NMLS ID # and registration current “to CYA”. I’m concerned his bonus may be non-compliant with Loan Originator Compensation requirements. Should I be worried?
03/24/2024
Our Board Chairman’s daughter has opened her own business and wants a loan from us. She is on it all by herself and he will not be a guarantor. Is her loan subject to Reg O?
03/17/2024
Who should manage the NMLS registration for our Mortgage Loan Originators (MLOs)? Is that an HR function, or should compliance do it?
03/17/2024
We have a Director who (together with his wife) shares ownership of a law firm. I just learned that we booked a $525,000 loan for that law firm. The loan has a rate and terms comparable to other loans. Is this a problem for Reg O?
03/10/2024
I work in operations, and our Executive Vice President just showed up on the daily NSF report! He has overdrawn his personal checking account by $1,200. What do we do?! Can we pay it or must we return it, and must we charge him our normal fee?
03/10/2024
Must our Loan Originators (LO) be registered on the NMLS Registry?
03/03/2024
To avoid Reg O conflicts, we are thinking of granting a loan to an executive officer that is secured by a CD at our bank. Does this type of collateral eliminate any Reg O concerns?
02/25/2024
Who is an “Executive Officer” under Reg O?
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