Three Simple Steps to Avoid the Staffing Spiral of Doom

Interesting (and brief) article on LinkedIn, Three Simple Steps to Avoid the Staffing Spiral of Doom. Good points, and I especially like their suggestions for job postings (#1) as we consider how we advertise our open positions. Also an excellent link to Do We Have a National Skills-gap Crisis? 6 Morsels of Food for Thought.

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Kiss or bow?

Apps that simplify travel:

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Cool site/service for getting a limo

Curious and eager to try this out. “Simply tell Pinpoint where you are now, where you are going, and when you want to leave. We will quickly connect you with a nearby sedan and give you a confirmed rate and pick up time. There is no cost to you for this service.” . iPhone app:

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13 Things You Must Do Every Week As A Startup CEO

Being the CEO of a startup is a hard and complex job. Here’s my quick list of the 13 things every startup CEO should make sure to do each week:

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Eight Habits of Highly Effective Google Managers:

“Wow, brace yourself. Because the directives might seem so forehead-slappingly obvious — so, well, duh — it’s hard to believe that it took the mighty Google so long to figure them out:
“Have a clear vision and strategy for the team.”
“Help your employees with career development.”
“Don’t be a sissy: Be productive and results-oriented.”

The list goes on, reading like a whiteboard gag from an episode of “The Office.”

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Android App Inventor

Drag & Drop prototyping on the Android:

Android App Inventor has blocks for just about everything you can do with an Android phone, as well as blocks for doing “programming-like” stuff– blocks to store information, blocks for repeating actions, and blocks to perform actions under certain conditions. There are even blocks to talk to services like Twitter.

Android App Inventor

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Chase/Wamu Regulation Z Violation?

A quick review of my current financial situation:  Same job, higher income, a perfect payment record, and a better FICO score (800+) than when the loan was originally approved.

From the guidelines issued by the Office Of Thrift Supervision (OTS):

Truth in Lending Act (TILA) / Regulation Z
With some exceptions, Regulation Z prohibits a creditor from changing any term of a HELOC account. Notably, however, a creditor may prohibit additional extensions of credit or reduce the credit limit during certain periods, as long as any reduction in a borrower’s credit limit below the outstanding balance does not require the borrower to make a higher payment. Consistent with Regulation Z, creditors may freeze or reduce a HELOC account when:
The creditor reasonably believes that the consumer will be unable to make payments as agreed because of a material change in the consumer’s financial circumstances. It is important to recognize that this exception requires both a material change in a borrower’s financial situation and the creditor’s reasonable belief that the borrower will not be able to repay the HELOC account as agreed.

So why has Chase/Wamu frozen this line of credit? Since my income is higher than when I obtained this HELOC, and my documented income is higher than that which I declared on this Stated Income / Verified Asset Loan (SI/VA) loan, it can’t be because “your income is significantly less than the income information provided when you applied for your credit line”.

Could it be that Chase/Wamu’s decision “was based on whole or in part on information obtained in a report from the consumer reporting agency [TransUnion].”? Let me take a look at my FICO score conveniently reported by the Chase/Wamu Website by TransUnion.

Wow – my credit score is excellent and unchanged – from their own website! It appears that Chase/Wamu has no actual evidence to support the Regulation Z’s requirement of a “material change in a borrower’s financial situation”.

Could it be that they just made this all up to close an under-used line of credit? Looks like I’ll also be filing a Regulation Z violation complaint with the FDIC.

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Frozen Chase/Wamu HELOC, Unprofessional or Deceptive Communications?

I noticed this morning that my Chase/Wamu HELOC has been frozen without notification.

I contacted customer service representative "Braden" (877-750-6825) for an explanation. I was told that the line of credit is "frozen" during this review period. I asked for confirmation in writing; he said he was "unable" to provide confirmation in writing – only verbally.

I find it at best unprofessional, at worst deceptive, that this "freeze" was never mentioned during my numerous calls to customer service, nor in any of the letters requesting additional information.

Unfortunately, this will cause me to scramble to fix any problems associated with their sudden change of commitment. I will try to post additional information when I can.

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Complaint Letter to Chase/Wamu

One of the Comptroller of the Currency (OCC) requirements is that I first attempt to resolve the issue with the lender. Since I was not able to solve this with additional calls to customer service, I asked for the contact information of their loan compliance officer (or department). The customer service represent instructed me to send my complaint to "Consumer Lending Support" at the same address as my previous correspondence.

I also confirmed with two separate calls to 877-750-6825 ("Ryan" and "Carl") that there is no suspension on the line of credit, the paystub and 4506-T forms had been received and were "being reviewed by underwriting, and will have a response in 30 days."

I sent the following letter on May 20th via USPS Express Mail with Delivery Confirmation:

Subject:  Flawed, Inappropriate, and Onerous Demand
Attention: Consumer Lending Support

The contents of my previous post, Flawed, Inappropriate, and Onerous Chase/Wamu 4506-T Demand?

Remedies that I require from Chase/Wamu Consumer Lending Support:

  1. Provide text with page and line number references from the original Terms and Conditions of this stated income, verified asset loan (SI/VA) that expressly permits Chase/Wamu to require new information not originally provided as part of this loan. If this documentation is required as part of "updated" information, provide evidence of the original paystub and tax documentation to be "updated".
  2. If Chase/Wamu cannot provide the above information, confirm in writing that both hard copy and any electronic copies of the documents have been destroyed.
  3. For all future requests, provide sixty (60) days notice with a thirty (30) day follow-up letter.
  4. Carefully review any future requests to prevent obvious errors like the ones referenced in this complaint.
  5. Refrain from backdating any future requests.

Please reply to this complaint in writing within fourteen 14 days of the date of this letter. Failure to respond satisfactorily within fourteen (14) days from the date of this letter will result in a filing with the Office of the Comptroller of the Currency (OCC).

I will keep you all posted regarding their response.

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Flawed, Inappropriate, and Onerous Chase/Wamu 4506-T Demand?

I received a letter from Chase/Wamu regarding a little-used Home Equity Line Of Credit (HELOC) on May 8th, requiring a 4506-T and a recent paystub by May 15th. I contacted customer service representative "Aaron" (877-750-6825) with questions.

  • I asked "Aaron" about the referenced 4506-T form, and he confirmed that the package I received was not complete; it did not include the pre-filled form 4506-T. "Aaron" said a corrected package would be sent out May 6th.
  • I asked "Aaron" why Chase/Wamu was demanding this as "updated information upon request" since the original loan was secured as a Stated Income/Verified Asset (SI/VA) loan, and did not require either tax returns or paystubs. He stated that these documents were required as part of the Washington Mutual takeover by JPMorgan Chase Bank. "Aaron" stated that I must provide this information by the due date or the line of credit would be frozen and later closed.
  • I asked that this issue be escalated, since I did not consider this additional information to be part of "updated" information. I was forwarded to "Bonnie" (888-800-8738), a Department Manager. I explained to "Bonnie" that my copy of the loan agreement stated that Chase/Wamu could request "a current financial statement, a new credit application, or both, annually". There is no mention of new information not required as part of the original loan. I asked "Bonnie" to mail me her copy of the loan documents which indicated that Chase/Wamu could request this new information.
  • I received the updated packaged from Chase/Wamu on May 12th. The letter was back-dated five days from the postmark date, and contained conflicting and erroneous instruction. For example, the text stated "We are requesting transcripts for the two most recent tax years", i.e., 2007 and 2008. The form 4506-T, however, was pre-filled with a request for tax years 2006 and 2007.
    The updated package still required a response by May 15th. Since the delivery address was a PO Box in Florida, this allowed me 24 hours to complete the form and send it by USPS Priority Mail.

Since I now had only 24 hours to fill out and mail the paperwork, and had not yet received the alleged legal text from "Bonnie", I sent the 4506-T and paystubs via USPS (with confirmation). I attached an additional cover sheet  with the following stipulation:

Upon review of my copies of the original "Master Loan Application" and "Home Equity Line of Credit Agreement and Disclosure", this form 4506-T is being provided "to comply with governmental reporting or legal processes" as per the terms and conditions of this stated income loan. Use of this information by Washington Mutual or JPMorgan Chase Bank for purposes other than those expressly permitted under the original terms and conditions of the "Master Loan Application" and "Home Equity Line of Credit Agreement and Disclosure" will be reported to the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC).

I am considering filing a complaint with the Office of the Comptroller of the Currency (OCC) for what I consider to be a flawed, inappropriate, and onerous demand. One of the OCC requirements is that I first attempt to resolve the issue with the lender. If I am not able to solve this with another call to customer service, I will send their loan compliance officer (or department) my detailed requirements for resolution. I will send these via US Mail and allow them 14 days to respond in writing before filing my complaint with the OCC .

Additional links:

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