Bio:
Rebekah is the owner of Elucidate LLC, a compliance training and consulting company. Elucidate means to "make clear, explain, throw light upon", and describes Rebekah's desire to illuminate the complexities of compliance with passion and fun. She's created and produced a TRID music video parody and several Compliance Breakout escape rooms, which she frequently provides at state banking compliance conferences. She is an accomplished speaker and regularly provides webinars through BOL and Compliance Resource.
Rebekah is currently serving as the VP Director of Compliance for a $6 Billion community bank in Montana. She began her career in 1995 at a private lending company, but soon settled into banking, where she's covered nearly all of it - customer service and teller work, loan processing and review, and security and business continuity. She now oversees CRA, BSA and all aspects of compliance as a senior leader. She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams.
Rebekah has a bachelor's degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006.
Questions Answered
10/27/2024
We have a credit card product that has an introductory “fixed” rate that changes after 12 months to a variable rate APR. Management wants to really promote that fixed rate period, but I don’t think we can use the word “fixed”, can we?
09/29/2024
Who is an “Executive Officer” under Reg O?
09/29/2024
We have a new employee who was registered as an MLO at another financial institution. Upon updating their NMLS registration for our employment, we learned their fingerprints are over 3 years old. Can they still originate loans with us?
09/22/2024
An auditor just told us we have an APR violation on a TRID loan, and we need to make restitution to the borrower. Don’t we need to send a corrected Closing Disclosure too?
09/22/2024
I’m so confused! I keep hearing about the “SAFER Banking Act”. How is that different from the “SAFE Act” from several years ago? Is it being updated?
08/04/2024
We are doing a change in terms to modify a consumer’s ARM loan. We are reducing the margin to make up for a higher index rate when the rate adjustment hits, and are resetting the adjustment period from 5 years to 3 years. The customer is benefiting from this change (the rate will actually go down just a touch), and they are signing a CIT agreement. Is this OK to do with just a CIT agreement?
07/28/2024
Can a fixed interest rate be increased with only a modification agreement? Or is a new note with new disclosures required since the rate is not being reduced?
07/28/2024
Are all banks examined the same way for compliance?
07/21/2024
We have a HELOC that has matured, and the customer is having trouble repaying. Can we do a workout agreement on it (reduce the variable rate interest to thereby reduce the payment and give them a breather)?
07/14/2024
I’ve been hearing a new mortgage ad slogan: “Date the Rate, Marry the Home”. What is this all about, and should we adopt it too? It is catchy, and might garner us some new loan apps.
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