Dan is Vice President and Compliance Officer for The Peoples State Bank with its main office located in Ellettsville, IN and supporting nine branches in surrounding communities. The bank is a privately owned bank that began its existence in 1904.
Dan entered the financial services arena in 1974 when he went to work for Commercial Credit Corporation. He worked eighteen years with Bank One and three years with the Indiana University Employees Federal Credit Union. In addition to serving as a Compliance Officer, he has served as a Collection Officer, Consumer Loan Officer, Commercial Loan Officer and Loan Operations Officer. His primary duties falls within lending compliance, training and consumer loan reviews.
He attended Three Rivers Junior College in Poplar Bluff, MO and Arkansas State University in Jonesboro, AR. He is also a graduate of the ABA Bank Card School, ABA Commercial Lending School and ABA National Truth-in-Lending Compliance School.
08/27/2023
I would like to know when exactly does a financial institution need to send the annual PMI notice? I understand that it can be included in the annual escrow statement, but if sent separately, what annual date should be used?
08/06/2023
How do other bank handle flood certifications on loans which are secured by an existing real estate mortgage on subsequent loans? For example: We do an original note secured by a mortgage. Two years later, the loan is refinanced, and new money is added. Do you require a new flood certificate for this increased loan? We do have life of loan on our flood certificates which notify of us flood map changes. We also have loans secured by GBSA (general business security agreement) as the main piece and real estate secondary. If our flood certificate is within 7 years and maps have not changed, do we need to do a new flood certificate? Can we just print out a section from FEMA's website as proof the maps haven't changed? We're trying to come up with procedures which keep us in compliance and uncomplicate the process we currently have.
08/06/2023
Would terming out a construction loan be considered a purchase on HMDA LAR?
08/06/2023
We have loan that has three applicants. One will live at the property but has no credit. The other two had the credit and income. Since there are only two places to record DOB and Credit Scores for HMDA, which ones do you use?
07/16/2023
A flood policy expired on a loan that had deferred principal due to a COVID Deferral program. The customer didn't renew their policy and force placement of coverage was implemented, notices went out on time and the force placement happened on day 46. The problem came one week prior to the renewal of the force placed policy, when evaluating to renew, it was discovered that the number used to calculate coverage last year was incorrect. The principal used was a much smaller amount which is the one agreed on the COVID deferral, but not the real one. Since the policy is a forced placed policy, and regulation doesn't require a new set of notices, we only send one courtesy letter advising the client of the imminent force placed renewal. My counterparts think that we should restart the letters since we will renew the policy for a higher amount but I don't agree with that assessment. What do you think?
07/02/2023
Our customer is requesting a closed-end draw down loan secured by stock for college expenses for a grandchild. Our Loan Origination System does not have the capabilitry of calculating repayment term disclosures for draw down lines of credit. Can we even proceed with this Private Education Loan as requested by the customer? There is no exception for draw-down loans, but disclosure requirements cannot be met.
06/18/2023
We recently discovered that we have a few ARM loans that were set up on our system incorrectly. The payment was not set to change when the rate changed. As a result, we have basically extended the amortization on these loans by not increasing the payment along with the corresponding rate increase. How would you suggest we rectify this error?
06/18/2023
I have a loan secured by property in a flood zone. It was originated 10 years ago, and therefore the flood cert exceeds the 7-year threshold. I am documenting a modification to change the rate index from LIBOR to SOFR which is resulting in a rate increase. The loan amount/balance is not being increased, extended or renewed. It is my understanding the rate increase/index change does not trigger a MIRE event, and therefore, I have no further requirements under flood associated with this modification. I am being advised that a rate increase (and payment increase) is included as part of MIRE ("increase"). While the regulation does not clearly state this, it is understood in the industry that this was not intended under the definition of MIRE. Could you confirm my understanding, and confirm I am not obligated to perform any further responsibilities under flood relating to this specific transaction?
03/19/2023
On the loan estimate, I input it as a balloon rather than installment which drastically increased the payment. Do I need to redisclose theis with a revised LE or do I make the correction in the closing disclosure?
01/15/2023
Under TRID rules the bank must send a copy of the appraisal three days prior to closing the mortgage loan. If the appraisal is sent electronically but the customer has not opened the email, has the bank met the regulatory requirements?