Abundance of caution – no flood insurance needed, right?
05/15/2022
Is flood insurance required on property taken as an abundance of caution?
Rebekah is a sought-after compliance expert, the VP Director of Compliance for $6 billion community bank in Montana, and the owner of Elucidate LLC.
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 Compliance Resource, LLC.
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.
05/15/2022
Is flood insurance required on property taken as an abundance of caution?
05/08/2022
We told our commercial applicant that his building is in a flood zone so he needs to purchase flood insurance. He hired a registered professional engineer and brought in an elevation certificate showing the lowest floor is above the Base Flood Elevation. Can we accept it? He is threatening to take his loan elsewhere if we don’t.
09/13/2020
How can my bank make sure we correctly classify our employees as a Mortgage Loan Originator or a Loan Originator? It is confusing
09/06/2020
Is my bank exempt from the anti-steering requirements (i.e. giving the applicant 3 other loan options) in the LO Comp rules of 1026.36?
08/30/2020
Our Executive VP earns a substantial annual bonus. He doesn’t really do any real estate lending, but he certainly talks with many bank customers (often on the golf course) about how the bank can provide various loan solutions, including home loans. Up to this point, he has kept his NMLS ID # and registration current “to CYA”. I’m concerned his bonus may be non-compliant with Loan Originator Compensation requirements. Should I be worried?
08/23/2020
Who should manage the NMLS registration for our Mortgage Loan Originators (MLOs)? Is that an HR function, or should compliance do it?
08/19/2020
We have started a new referral program to pay bank employees a modest fee to send possible borrowers to our real estate department. Can we do this?
08/16/2020
Must our Loan Originators (LO) be registered on the NMLS Registry?
08/02/2020
My bank is a small creditor who makes HPMLs. We’ve been claiming the escrow exemption, but now I’m not so sure we should. Sometimes we set up accommodation escrows for extenuating circumstances – does that cause problems?
07/26/2020
Our community bank is opening a new branch in a bigger city. Will we lose our “rural and underserved lender” status?