Bio:
Mr. Andy Zavoina, CRCM, is 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 is a frequent webinar presenter for BOL Learning Connect and 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.
Questions Answered
07/21/2003
We have an interestbearing money market account that we do not pay interest on if the balance falls below $1,500 for the statement cycle. Is that in violation of Reg DD? The reason I ask is I was reviewing some training materials and read the following: "Interest must be calculated on the full amount of principal in the account each day. 'Low balance' and 'investable balance' methods are prohibited." If we are not in violation, can you explain to me what that sentence means?
07/21/2003
I know it is necessary to issue an ECOA Adverse Action Letter if an applicant does not accept a counter offer. I also know that Reg B allows an applicant up to 90 days to accept the counter offer. My question is this If an applicant ACCEPTS the counter offer, is an Adverse Action letter required for the original request?
07/21/2003
If a check card customer disputes a charge and we are forced to pay the claim, can we refuse to reissue the card? I am under the impression that we were not allowed to refuse issuance of another card if the customer exercised their rights under the regulation to make a claim against fraudulent activity on their account. It is my understanding that in order to not issue another card we have to come up with another valid reason or prove the customer was negligent in the use of the card. Is this correct?
07/21/2003
I am currently performing an audit on escrow analysis. I am having difficulty in one area and would appreciate any assistance you may provide. Section 3500.17(d)(1)(B) states "...add to the first monthly balance an amount just sufficient to bring the lowest monthly trial blanche to zero, and adjust all other monthly balances accordingly." When I view Appendix E for an example, I am confused because the balances they end with under aggregate analysis is not zero, which I feel would be appropriate. However, they end with a balance of $780 (NOTE: we do not apply a cushion). How does this affect the surplus refund of $50 or more at the end of the computation year? Is this surplus on top of this adjusted balance to eliminate any negative balances or is the surplus referencing the ending balance?
07/14/2003
As it pertains to responsibility for CRA for an institution, such as the CRA Officer, what department does this position usually fall under at most banks? We are $470 million and are reorganizing. Right now it's under our lending area and they are considering to make it a part of marketing...I think it should be a part of our compliance department. Of course marketing would provide updates to compliance on community outreach.
07/14/2003
What are some restrictions and policies to adhere to when beginning the thumbprinting program to reduce fraud? Also, what areas of compliance should be followed? Do we have to post signs at tellers' windows and change disclosure brochures?
07/07/2003
We are new to internet banking. We have our customer statements as part of our online product. The statement has a complete copy of our mailed version. We have customers asking us to stop their paper copy. What are the rules and to start this what would need to do.
07/07/2003
My question is in regards to Regulation E vs Visa. I am under the understanding that if a transaction is PIN based it follows Regulation E's time frame and liability, but if it is Visa based transaction it would be under Visa's time frame and liability, which is zero. Am I correct?
07/07/2003
We are looking for a source that would gives us the details on compliance disclosure required if we display loan rates on our web site.
07/07/2003
With the change of Reg P (Bank Protection) to Reg H and the implementation of information security procedures under GLB, what is your feeling about how annual reports on security should be made to the Board? Should there be a separate physical security report and a separate information security report or should they be combined for an overall security report?
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