Kimberly is an industry-leading trainer and currently serves as the Director of Risk and Compliance at Compliance Resource, LLC. She has more than a two decades of experience working in the financial services industry. Ms. Boatwright is a well-regarded financial industry risk and compliance professional with a strong background in program development and implementation. She is a thought leader who specializes in Fair Lending, Anti-Money Laundering, OFAC and consumer compliance. During her career she has worked for and consulted with all types of financial institutions helping to establish and evolve compliance and risk programs. She is a frequent public speaker, trainer, and author on compliance and risk management topics. Kimberly is a Certified Regulatory Compliance Manager and a Certified Anti-Money Laundering Specialist
05/04/2025
When advertising a 7/6 ARM product on a website is it acceptable to just show a payment amount per $1,000 based on a loan amount of $215,000 along with the interest rate and APR or should the payment be shown after the seven-year initial fixed-rate period as well to be in compliance?
04/27/2025
We are refinancing a construction loan to an amortizing monthly payment loan effective March 18, 2025 (the maturity date of the construction loan). Our early disclosures are dated 3/18/2025. Since closing must be at least seven days later, can we date the note March 18, 2025, even though the actual closing date will be April 4, 2025? If we can date the note March 18, 2025, does the customer have to pay interest from March 18 to April 4.?
04/27/2025
We are considering putting our loan applications online as a PDF because we get asked a lot if we offer this. I am having trouble locating the do's and don'ts of this. Can someone please guide me in the right direction?
03/23/2025
What is the correct TRID purpose for placing a manufactured (double-wide) home on land that is owned free and clear? The loan was closed with the purpose of combining the value of a new factory built manufactured home and the value of the land on which it was located immediately after closing. In order to assure the manufactured home dealer would deliver and set up the home on the land timely, the dealer was paid in three disbursements from the borrower’s proceeds which were held until a final inspection was completed. The loan was not closed as temporary financing, but to purchase the home and place it on land. We used “Home Equity” on the Closing Disclosure, but we are being questioned as to why we did not use “Construction” since we made three disbursements from the proceeds. They were not true “advances” from the principal of the loan, but rather three disbursements from the borrower’s proceeds. We close two separate loans for true construction loans for homes built from the ground up; one being 12 months interest only and the other being a refinance of the construction loan for permanent financing. We have offered combination manufactured home and land loans for many years and have not been cited for our handling of the TRID purpose until now. I think the auditor was triggered by the use of the terms “advance” and “undisbursed loan funds” on the Closing Disclosure to show the amount paid to the dealer at closing and the amount we were holding. We have since changed our terminology to use “payment” and “funds held.”
12/22/2024
I actually referenced these as well which is what I used to support my interpretation; however, the other interpretation I heard the reason they said they got to that was following the citations along with the HMDA reportable transaction exclusions. So 12 CFR § 1002.104(b)(2) then if you go to the citation referenced there 12 CFR 1003.2(e) then go to the 1003.3 (C) referenced there. So looking at those exclusions it doesn’t mention anything in regards to if your bank is in an MSA or not but #11 references FI that have fewer than 25 loans. Hence, that being their reasoning that the only way non HMDA banks would exclude HMDA transactions was if they were non-HMDA due to loan volume. I’m not disagreeing with your answer because that was our interpretation as well but when following the citations that they used to come up with their interpretation and can see why they would maybe think that.”
12/15/2024
We have a question on the 45 day letter/forceplacement time frames. Can you give an example of the timing when a policy expires on 12:01 am on April 1st. The 45 day letter would go out on the 1st, when would you actually forceplace; the 46th day after the date of your letter? Please also clarify the FEMA lapses due to funding. Were you saying that if we have a FEMA policy in place and the government lapses the program, we are required to have them obtain a private policy or we need to start our 45 day forceplace process until the government reinstates the program?
12/15/2024
My FI has never had HMDA issues before; why do I need this course?
12/15/2024
I heard there were three major HMDA CMPs, what caused them?
12/15/2024
Are you one of the 1,700 HMDA reporting institutions that was required to start collecting and reporting data ? Here’s where to start.
12/15/2024
Do you think you have gaps in your fair lending and CRA program?