Flood CMPs in 2023
12/03/2023
What has happened to flood penalties in 2023?
Andy Zavoina | CRCM
Bio:
A seasoned expert, Andy has taught compliance for more than 20 years - he also helped build BankersOnline into the industry-leader it is today.
Andy Zavoina, CRCM, was an Executive Vice President and Chief Relationship Officer with the Glia Group, Inc., best known for its interest in BankersOnline.com. He joined Glia and BOL in 2003.
Mr. Zavoina has been in finance and banking for 42 years. Over 20 years were with a two-bank holding company which had $534 million in assets, 89 branches spanning Texas and nearly 500 ATMs. He managed loan workouts, has been a consumer, commercial and real estate lender, managing those departments, as well as being his banks first Webmaster. He was responsible for compliance -management, -auditing, and -training for both banks.
Andy was a frequent webinar presenter for BOL Learning Connect and is a key contributor to conferences put on by BOL Conferences, Inc. In addition, Andy teaches live presentations at state association schools and regional compliance organizations across the U.S. and has served on the faculty of national banking schools. He has written articles and lectured on many facets of compliance, the use of the internet and technology as a tool, as well as compliance in cyberspace.
As a BankersOnline Guru, Andy assists banks in every day, and not so every day, compliance questions on BankersOnline, BankCompliance.com and other organizations.
Mr. Zavoina is a recipient of the American Bankers Association’s Distinguished Service Award for his involvement and accomplishments in the field of regulatory compliance management. He is a past Chairman of the ABA’s Compliance Executive Committee, the Editorial Advisory Board for the ABA Compliance Magazine and served as a member of the ABA’s Compliance School Board. He also served on the Texas Bankers Association's Compliance Committee.
He is a graduate of the ABA National Commercial Lending School, National Compliance and National Graduate Compliance School and is a Certified Regulatory Compliance Manager with the Institute of Certified Bankers.
Contact info:
You can reach Andy on the Internet by using his e-mail address, andyz@bankersonline.com, or visiting http://www.bankersonline.com.
Questions Answered
Website Change Management
12/03/2023
We currently keep both electronic copies and paper copies of every change made on our website. This is time-consuming to maintain. How critical is it to keep hard copies of our work, and what questions should we be asking ourselves to potentially reduce or eliminate unnecessary paper trails?
From social media to the website
11/26/2023
We include the EHL logo on our website where we offer home loans. We also use Twitter and Facebook, but do not use it there because it is on our site. Are we OK?
Weblinking Requirements
11/26/2023
Do weblinking rules apply if a business has a link to us, and are we required to monitor this?
Send E-SIGN with Disclosures
11/19/2023
What is demonstrable consent and can we do that with new account disclosures we email the new customer?
Remember the SCRA when reporting loan history
11/12/2023
Can we report a past due loan to the credit bureau when SCRA protections apply?
MLA - Open-end and ODP Coverage
11/12/2023
The Military Lending Act does not specify if the Act applies to an open-ended Overdraft Protection line that is tied to a checking account or a closed-ended loan secured by the applicants’ deposit accounts such as a savings and/or certificate of deposit. Does the Rule apply to both consumer credit types?
Military Status and Foreclosure
11/05/2023
If our borrower hasn’t requested SCRA protection and is past due on her mortgage, can we start foreclosure as we normally would?
When is the appraisal rights notice required?
11/05/2023
There is confusion over the disclosure for the Reg B, Right to Receive Copy of Appraisal. I read that David Dickinson (Aug 9, 2010) said there is no date requirement for this disclosure, whereas Dan Pesfull advised it is given at or within 3 days of application but can be given at closing. Per the CFPB website it must be given within 3 business day of receipt of application. (12 CFR § 1002.14(a)(2). Can some one clarify.
SCRA Rates and Limit Increases
11/05/2023
I have a member who has a credit card with us. He recently notified us that he is now active duty. I know what our responsibility is regarding the interest rate under SCRA because this is a pre-service obligation. He now wants a limit increase of several thousand dollars on his credit card. Must we give him 6% on that portion?