Bio:
Michelle Strickland brings a wealth of commercial, consumer and
residential loan compliance to her position at TCA, Thomas Compliance
Associates, Inc.
Like many now senior compliance officers, Ms. Strickland began her
banking career on the teller line, but her early career also included
consumer, residential and secondary market loan processing. Her next
step up was as a systems administrator for six bank branches; Ms.
Strickland’s responsibilities included customizing the bank’s loan
origination systems.
Ms. Strickland’s most recent experience, at a large Indiana bank, included
responsibility for three operational areas: loan servicing; commercial
loan processing and documentation; and residential and consumer loan
processing and documentation. Her duties included the preparation of
Risk Assessments on loan operations functional areas, vendor
relationships, pipeline reports and, of course, regulatory compliance.
Ms. Strickland joined TCA in early 2014.
Questions Answered
05/12/2024
Can you provide guidance on what is considered an outside source? On the Notice of Action Taken in the Disclosure of Use of Information Obtained from an Outside Source, what would be considered an outside source. We have a customer where the denial is based on “Collection Action or Judgment” which was identified when the account officer did a search through our State’s website. Would this constitute such a disclosure and if the borrower wanted to request a copy as they have a right to would we simply give them the name of the website?
05/05/2024
If a loan is denied based on collateral but our credit reports include the credit score, is there anything wrong with include the applicants score on the Notice?
04/28/2024
A customer applied for a HELOC and the Bank decides not to approve them due to their declining financial condition and offered a closed end home equity loan. The customer declined the offer, paid off the HELOC and went elsewhere. Is an Adverse Action Notice required?
04/21/2024
How would a commercial application denied based on the DTI of the guarantor be handled? In this case, the credit report of the guarantor was used to determine their debt level.
03/24/2024
We are making a construction loan to a business to construct their new corporate office. Because the building is not yet constructed, do we need to do a flood determination?
03/17/2024
Our loan amount is $1,000,000. According to the hazard policy, the replacement cost value of the building is $1,500,000. We only have $500,000 coverage on the building and our internal auditor has indicated we need more coverage. Is this true?
03/10/2024
Is flood insurance on the contents of a property required if the property is located in a SFHA?
03/03/2024
We made a loan to a borrower for the purchase of 2 mobile homes located in a mobile home park in Florida. The homes are “strapped down” to meet state/local requirements and have electricity and plumbing. However, we feel the home can be disconnected and moved and would not require us to perform a flood determination. Are we correct?
02/25/2024
We are making a loan to a business customer to purchase a new apartment building. The apartment building is not located in a flood zone. The loan approval requires the cross collateralization of two additional properties owned by the borrower. Do I need to obtain flood determination on these properties?
02/18/2024
We have a commercial loan on farmland with 12 outbuildings and a dwelling. Only one of the buildings (a small barn) is located in a flood zone that requires insurance. The loan amount is $500,000 and the appraiser valued this building at $70,000. Because only a small percentage of the secured collateral is in a flood zone, is flood insurance still required?
