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Identity Theft Consultant, Expert Witness |
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The Facts on FACTA: Note Regarding Current FACTA Litigation
The United States Congress passed the Fair and Accurate Credit Transactions Act (commonly referred to as the FACT Act or FACTA), and FACTA was signed into law on December 4, 2003, and went into full effect on December 4, 2006. An important part of FACTA deals with the truncation of personal confidential financial information from printed credit card receipts. FACTA requires the truncation or masking of all of the credit card account number except for no more than the last five digits and the truncation or masking of the entire credit card expiration date. The vast majority of retailers do comply with FACTA and show on their printed credit card receipts only the last four digits of the credit card account number and none of the expiration date.
It is an inexplicable and unfortunate fact that many retailers willfully have chosen to ignore the credit card receipt account number and expiration date truncation requirements of FACTA and therefore needlessly subject their customers to the possibility of becoming identity theft victims.
Even though it is a proven fact that the costs of compliance with FACTA's credit card account number and expiration date truncation requirements are small, the possible resulting damages to a customer who becomes an identity theft victim as a result of a retailer willfully ignoring the requirements of FACTA are huge.
Likewise, it is in the best economic interests of retailers to make sure that their IT systems are set up to issue credit card receipts that comply with the credit card account number and expiration date truncation requirements of FACTA. Mr. Coker is available to consult with retailers and IT companies who need assistance in modifying their IT systems so that the credit card receipts they issue conform to the requirements of FACTA.
Mr. Coker provides expert consultation, examination and analysis of the facts of a case, advice, Declarations, reports, and sworn testimony in deposition and court for parties engaged in litigation involving FACTA matters.
Mr. Coker's expert witness experience and background includes oveer 365 cases, 93 testimonies, and 10 courthouse settlements in all areas of banking, finance, real estate, economic damages, business valuation, intangible asset valuation, and many related matters since 1989.
In addition to FACTA litigation and other banking and finance-related litigation consulting, Mr. Coker provides consulting services in many additional areas including business valuations, business plan writing, feasibility studies, marketing studies, anti-money laundering policies and procedures, policy and procedure manuals for financial institutions and other businesses, merger and acquisition due diligence and assistance, research, international matters, and many other related areas.
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Credit Card Expiration Dates and FACTA
By Don Coker
The Fair and Accurate Credit Transaction Act (“FACTA”) was passed by Congress and signed into law on December 4, 2003, and became fully effective on December 4, 2006. The purpose of FACTA is to reduce the amount of personal confidential financial information that is generated and thereby reduce the incidence of identity theft and credit card fraud. In keeping with this goal, 15 USC 1681c(g)(1) requires that merchants that issue receipts to individuals truncate all but the last four or five digits of the customer’s credit card account number and truncate the entire expiration date.
Unfortunately, and despite the fact that FACTA was widely discussed before and after its passage, many merchants simply have ignored these aspects of FACTA, apparently based upon their belief that expiration dates are unimportant to a criminal. They are wrong. Credit card expiration dates are very important and useful to criminals. Consider the following:
● Expiration dates are one of the inputs needed to calculate the 3-digit security code (CVV2 or CVC 2) on the back of a credit card.
● Expiration dates are required for some, but not all, online purchases, as clearly demonstrated by my recent online test purchase at Wal-Mart, the world’s largest retailer.
● Expiration dates combined with the last four or five digits of an account number can be used to bolster the credibility of a criminal who is making pretext calls to a card holder in order to learn other personal confidential financial information.
● Expiration dates are solicited by criminals in many e-mail phishing scams.
● Expiration dates are one of the personal confidential financial information items trafficked in by criminals.
● Expiration dates are described by Visa as a “special security feature.”
● Expiration dates are one of the items contained in the magnetic stripe of a credit card, so it is useful to a criminal when creating a phony duplicate card.
● Expiration dates are easy to exclude from receipts and involve minimal expense, even for a major retailer with hundreds of stores and cash registers.
● Expiration dates are required to be excluded from printed receipts, according to Visa’s Rules for Merchants, which predates FACTA.
● Expiration dates are required to be excluded from printed receipts, according to MasterCard International’s Rules, which predates FACTA.
● Expiration dates are required to be excluded from printed receipts given to individuals, according to laws passed or introduced in at least thirty-four states.
● Expiration dates are required to be excluded from printed receipts given to individuals, according to FACTA.
The costs for a merchant to implement FACTA are small, but the potential losses to individuals from identity theft and credit card fraud are great. Accordingly, it is difficult to see how any merchant could fail to see the risk of harm to which they willfully are exposing their customers by not truncating expiration dates as required by FACTA as well as Visa and MasterCard International merchant rules as well as many state laws.
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Don Coker is an experienced banking expert witness consultant who has worked on over 365 cases nationwide and testified 93 times. He is a former banker and banking regulator, widely published, and often quoted in the media. He is available to discuss FACTA and other banking, finance, economic and credit damages, fraud and embezzlement, real estate, business valuation, and related cases with attorneys. Mr. Coker is located in Atlanta, GA, and can be reached at Bankexpert@cs.com or (770) 852-2286.
© 2008 by Don Coker
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Identity Theft, Credit Card Fraud, Check Fraud & Credit Damage
An Article by Don Coker, Banking Consultant
Ms. X, a successful working single parent with perfect credit, obtained a mortgage loan to buy a home. A couple of years later, she began to receive notices of bounced checks from her bank where she had banked for several years. In investigating this with the bank, Ms. X learned that there were numerous debits from her account, in the form of checks bearing her forged signature as well as other debits that she had not authorized. The problem extended to her credit card accounts where items were purchased without her authorization. Furthermore, Ms. X later learned that completely new credit accounts had been opened in her name based upon her other credit information. These fraudulent accounts in her name were now delinquent and reflected on her now horrible credit report. Ms. X's credit picture went from perfect to unacceptable in a short period of time.
After a great deal of investigation and some lucky coincidences, it was discovered that the mortgage lender routinely maintained a copy of all their borrower's credit files, including Ms. X's, in their originating branch office for two years and then discarded it. This I where the problem came in: An employee (or employees) of the company hired to destroy and discard the files had hung onto several of them, including Ms. X's file, and used them to commit financial crimes.
What did Ms. X do wrong?
Nothing.
What could Ms. X have done to prevent this crime from happening?
Nothing.
What could the mortgage company have done to prevent this from happening?
Properly discard the file by destroying it onsite.
But the problem is certainly much broader and deeper than a few dumpster divers. The information needed to commit financial crimes is available from many sources. Retail clerks, credit card company employees, bank employees, and many, many others handle immense volumes of this information everyday. And then there's the Internet. I myself decided to make one purchase on the Internet - a scanner. A year and a half later, I noticed a charge item on my credit card account that I had not made. In checking into this, the credit card company quickly recognized the genesis of the problem as the scanner purchase I had made a year and a half ago, since someone had hacked into the computer equipment retailer's website and stolen credit information about their purchasers.
In my practice as a Banking Consultant and Expert Witness, I have experienced a growing volume of calls regarding the associated problems of credit card fraud and identity theft. Unfortunately, identity theft is a high growth industry.
The problems began as rather unimaginative criminals picked up credit card numbers and expiration dates from discarded receipts, through their work as a retail clerk, etc., and used the information to make a few purchases until the crime was discovered, and the use of the card or account number halted. Over time, this practice progressed (?) to the point that criminals became a little more imaginative and began to use the information from a stolen credit card or illicitly obtained account information to open new credit accounts and bank accounts as well. This was the beginning of what has been named "Identity Theft."
A further confounding factor is that criminals that commit these crimes usually view the stolen funds as "found money" and spend it on frivolous items such as 900 telephone calls, gambling, and unneeded retail purchases. Obviously, even if the criminal is caught, this makes any recovery difficult.
Warnings to individuals are everywhere as to how to logically reduce their exposure to credit card fraud and identity theft, all of them basically common sense. Let's look at what financial institutions and businesses can do to reduce the chances of these crimes succeeding:
1. Safeguard all sensitive information. This is not as easy as it sounds. A loan or credit file, which contains a credit report and other financial information, always resides in a walk-in vault. This means that anyone who is authorized to go into the vault can obtain this information. Also, obviously, files are taken out of the vault for various necessary and legitimate reasons, such as for loan servicing, tax, insurance, collection, etc., needs.
2. Any sensitive information that is being discarded should be shredded on-site by the personnel of the bank or other credit or financial services company. There is no reason to go outside the company and hire a contractor to destroy discarded files. After all, what we are talking about here is basically throwing away the trash in an appropriate manner. Any bank or financial services company or retailer should be able to do that without any problem and without bringing in an outside contractor to do that simple job.
3. Furthermore, sensitive materials that are to be discarded should be discarded as soon as possible after they are no longer needed. In other words, there is no valid reason to hoard files that are to be discarded until there is a sizable volume of them (as some financial institutions do). Destroy them as soon as they reach the date at which you have determined they should be destroyed.
4. There is no excuse for any receipt to display a credit card account number and expiration date. No bank or other credit card processor should operate this type of system. Likewise, no merchant should contract with a credit card processor who sells a system that displays this information on a customer's receipt which can then be thrown away and picked up by a criminal. (How hard is it to reconstruct a torn-up credit card receipt?)
5. Lenders and credit grantors can use some common sense when examining the account records after one of these crimes is reported. For example, it is not very likely that a married couple in their sixties is likely to have bought twelve rap CDs all of a sudden. Of course, it could happen (gift for grandchildren), but chances are it is a fraudulent purchase by a criminal. Likewise, it is unlikely that someone who has a perfect credit history for several years all of a sudden goes hog wild buying things they cannot afford.
6. Similarly, lenders and credit grantors should immediately freeze or shutdown accounts on which suspected fraud is reported. If they do not, then the victim can reasonably claim that they were further damaged by the financial institution's failure to freeze or shut-down their account.
7. Credit bureaus can do a better job in this process if they would not allow their clients, i.e., the merchants that report credit information to them, to re-report erroneous credit information. When erroneous credit information is found on a credit report, a credit bureau will usually remove it (after the individual begs for awhile), but then the next tape or data feed from the merchant that originally reported the erroneous information will often contain the same erroneous information. The victimized individual thinks that they corrected the problem with the first removal, but is unaware that the erroneous information will be reported again the following month.
Identity theft and credit card fraud can strike anyone anywhere. I have seen cases involving untrained, untalented, unfortunate people who already have horrible credit and bounce around from job to job, and cases involving people of the caliber of the former managing partner of a major law firm and several United States Senators.
Some of the victims have the added problem of having had credit problems before, so any problems that surface regarding their credit are viewed initially as highly suspect. So someone who has experienced a temporary and corrected financial problem can have all of that effort erased by being victimized by these crimes.
And of those who are victimized by these crimes, I have never known of even one to achieve a true correction and restoration of their credit history. Accordingly, damage of this type endures for a long, long time, even beyond the seven years beyond which a bankruptcy and other negative items should disappear from a credit history.
The problem apparently comes in with the official starting date of the seven years since credit grantors try to bump this date forward every time they have a contact with someone or receive a payment or experience any account activity.
Credit grantors and credit users must both take all prudent steps to safeguard access to financial records. Likewise, speed in reporting by credit users and speed in responding by credit grantors is essential. It is important to recognize that each one of these crimes begins with the discovery of a single fraud event. The sooner it is reported, the accounts handled properly, and everyone begins operating on a heightened level of awareness of the problem, the sooner the fraud can be shut-down and damages to all parties minimized.
Copyright 2002-2008 by Don Coker
About the Author
DON COKER is an Atlanta-area based Banking, Management, Economic and Valuation Consultant who has assisted clients in 45 states and internationally in 23 countries in the Americas, Europe, Asia, and Africa. His clients include numerous banks, insurance companies, governmental bodies, corporations, individuals, and law firms.
Clients include The World Bank, Bank of America, Bank One, JPMorgan chase Bank, Wachovia/SouthTrust/First Union Bank, US Bancorp, KeyCorp, Goldome Realty Credit Corp., Southeast Bank, Southwest Bancshares, American Savings & Loan, AIG Insurance, CNA Insurance, Reliance Insurance, Lloyds of London, Crum & Forster, National Union Fire Insurance, Continental Casualty Insurance Co., Acadia Insurance, FDIC, RTC, FHLBB, Internal Revenue Service, State of Texas Savings & Loan Department, City of Orange, CA; Zapadnoe Koltze (Tagliatti, Russia); Ruby Tuesday; George Kaiser (Forbes 400 List); Gary Tharaldson (Forbes 400 List), Jones, Day, Reavis & Pogue; Vinson & Elkins; Dorsey & Whitney; Baker & Hostetler; Holland & Knight; Carlton Fields; DLA Piper Rudnick; Baker Botts; Fulbright & Jaworski; and Stradling, Yocca, Carlson & Rauth, and hundreds of others.
Consulting Issues include all banking and financial services areas, investment banking services, D&O cases, lender liability, industry standards and practices, money laundering, white collar crime, embezzlement, fraud, forensic funds tracing and transaction reconstruction and analysis; commercial real estate issues, financing, site selection, and feasibility; corporate finance issues, hospitality industry issues, and management consulting issues; and the valuation of tangible and intangible assets including businesses, professional practices, healthcare entities, stocks, intellectual capital, trademarks, contracts, lost profits and wages, economic damages, and other unusual assets.
Mr. Coker is a specialist at calculating economic damages.
Mr. Coker's Background includes high-level management and regulatory responsibilities, numerous Expert Witness assignments (365+ engagements, 93 testimonies, 10 courthouse settlements), business books and articles published in professional publications, and inclusion in Who's Who in America and Who's Who in the World.
Notice to Identity Theft Victims:
Please note that Mr. Coker does not dispense free advice. If you have been the victim of Identity Theft, you should immediately discuss the matter with your banks and other credit grantors. If this does not resolve the problem, then engage an attorney to assist you. This may also include involving law enforcement.
After you engage an attorney, if the attorney feels that litigation is required in order to resolve your problems, then he or she may contact Mr. Coker. He assists attorneys for Plaintiffs and Defendants in Identity Theft cases nationwide.
Mr. Coker provides a wide range of consulting services to clients nationwide and internationally. Areas of consulting expertise include banking, management, economics, valuation of tangible and intangible assets, business valuation, investment banking services, assistance in international transactions, and litigation assistance.
REPRESENTATIVE CLIENT LIST
Banking:
The World Bank
Citigroup/CitiFinancial
Bank of America
Bank of America - Canada
NationsBank
MBNA America Bank
Bank One
JPMorgan Chase Bank
First Union Bank
Wachovia Bank
SouthTrust Bank
Washington Mutual Bank
U.S. Bancorp
Firstar Bank
Provident Bank
Credit Suisse First Boston Mortgage Capital, LLC
Bank of Oklahoma
Sunbelt Savings
Sunbelt Federal Bank
Bluebonnet Savings
Standard Pacific Savings Bank
First National Bank of Brewton
Southeast Bank of Miami, FL
Barnett Banks, Inc.
Bank of the Southwest
Priority Bancorp
KeyCorp
Tanzania Institute of Bankers
Bank of Tanzania (central bank)
Goldome Realty Credit Corp.
Western Gulf Savings & Loan
American Savings & Loan
EDS - BEI Golembe (Banking) Consultants
Governmental:
FDIC
Resolution Trust Corp.
Federal Reserve Bank of Atlanta
Federal Savings & Loan Insur. Corp.
Federal Home Loan Mortgage Corp.
U.S. Department of Education, Inspector General's Office
Farm Credit Bank
State of Texas, Savings & Loan Department (Regulators)
Internal Revenue Service,U.S. Treasury Department
Ten Municipalities in CA and CO
Tanzania Revenue Authority (tantamount to IRS)
U.S. Air Force, Judge Advocate General's Corp, Office of Special Investigations (Guantanamo Bay, Cuba)
New York Governor George Pataki's Office of Regulatory Reform
Insurance:
AIG
CNA
St. Paul Travelers
State Farm
Liberty Mutual Insurance Co.
Reliance Insurance Co.
Lloyds of London, UK
Acadia Insurance Co.
Employers Mutual Insurance Co.
Military Premium Managers
Physicians Mutual Insurance Co.
Physicians Life Insurance Co.
International Transport Intermediaries Club, Ltd., UK
North River Insurance Co.
Physicians Mutual Insurance Company
Physicians Life Insurance Company
American Casualty Insurance Co.
National Union Fire Insurance Co.
Continental Casualty Insurance Co.
Crum & Forster Managers
Xerox Financial Services
Thomas Miller & Company, UK
Corporate:
Cisco Systems
IBM - Lotus Development
Wal-Mart Stores, Inc.
Wal-Mart Real Estate Business Trust
Sprint/Nextel
Intuit - Quickbooks
Network Software Associates
NAPA Auto Parts
Darryl's Restaurants
Sears
Heritage Motels. Inc.
Calco Aerospace
Ruby Tuesday
Remington Investments
Phivos Karnaos (London & Moscow)
Jancik Concrete Specialties
George B. Kaiser, Forbes 400 List
Concord Boat Corp.
Houlihan's Restaurants
Fillette Green Shipping
Zapadnoe Koltze (Russia)
Benchmarking Partners
Gary Tharaldson, Forbes 400 List
Kilimanjaro International
Boston Credit Corp.
Past Professional Memberships
American Bankers Association
American Institute of Banking, Chapter Officer and Bank Consul
U.S. League of Savings Institutions
Institute of Financial Education, Instructor
Mortgage Bankers Association
Texas Mortgage Bankers Association
American Council of State Savings Supervisors
American Bankruptcy Institute - Committee assignments: Public Companies, Real Estate, International, U.C.C., Commercial Fraud Taskforce, Healthcare.
Board of Realtors
National Association of Homebuilders
International Council of Shopping Centers
Houston (TX) Chamber of Commerce, Economic Development Committee, 9 years
Books, Publications & News Media
Complete Guide to Income Property Financing & Loan Packaging, Prentice Hall, 1984.
Self-Management: A Guide to Career Advancement and Development, written under contract for Prentice Hall, 1985.
Complete Real Estate Computer Workbook, Technical Editor, Prentice Hall, 1986.
The Complete Loan Officers Handbook, presently writing.
"Money Laundering: A Dirty Business," White-Collar Crime Reporter, Oct. 1991.
Treasury Magazine published by The Economist. Interviewed and quoted in an article written by a U.S. News and World Report Editor.
"How You Can Help Your Client Get a Loan to Finance Real Estate Projects," Practicing Attorney's Newsletter, April 1984.
"Getting a Grip on Core Deposit Intangibles," American Banker newspaper, 1996.
"The Dollars and Sense of Business Valuation," published on the website of the American Bank Attorneys Association, April 1996.
"Putting a Cash Value on a Business," interviewed by Lawyers Weekly, May 6, 1996.
"Business Valuation Techniques," Business Locator, May 1996.
"Valuing Businesses," TAB Letter, Technical Assistance Bureau, June 1996.
"Using Business Value to Achieve Ad Valorem Tax Reductions on Commercial Real Estate Properties," Journal of Property Management, June 1997.
What's Working in Credit & Collection, interviewed, quoted re: bank drafts, March 1997.
"Making Sense of Internet Stock Values," TAB Letter, July 1999.
Africa Today, extensive video coverage by Reuters News Agency of Tanzania Revenue Authority training program, Arusha, Tanzania, March 11, 2001 and other dates.
Interviewed by ITV Television Network on the subjects of banking, taxation, economic growth and development, and capitalism in Tanzania, in Arusha, Tanzania, March 16, 2001. Aired on March 17, 2001, and subsequent dates.
The Atlanta Journal-Constitution, interviewed for an article on banking regulatory policies and procedures, and banking practices, August 21, 2001.
The Atlanta Journal-Constitution, interviewed for an article on banking practices and procedures to help deter terrorism, September 19, 2001.
The Atlanta Journal-Constitution, interviewed for an article on banking practices and procedures involving funds transfers and money laundering by terrorist groups. September 21, 2001.
The Baltimore Sun, interviewed for an article regarding considerations for the future of Allied Irish Banks, PLC's, American subsidiary Allfirst Bank. May 30, 2002.
The Atlanta Journal-Constitution, interviewed for an article on the effects of the Sept. 11, 2001, terrorist events on banking practices and procedures, August 29, 2002.
Credit and Collections World magazine and website, interviewed regarding bank account opening practices and identity theft, September 20, 2002.
Outside the Lines television show and ESPN.com website, interviewed regarding identity theft matters. November 1 - 3, 2002.
Lending Intelligence magazine and website, interviewed regarding lending practices and interest rates, November 25, 2002.
NBC Evening News, interviewed regarding identity theft, November 25, 2002.
Lending Intelligence magazine and website, interviewed regarding credit scoring and loan approval policies and procedures, December 10, 2002.
Charlotte Observer newspaper, interviewed regarding bank branching and operations policies, January 21, 2003.
Street & Smith's SportsBusiness Journal, interviewed regarding business ethics and corporate governance issues involving the U.S. Olympic Committee's Chief Executive Officer, February 25, 2003.
Family Finances column that appears in The Boston Herald, the Pittsburgh Post Gazette, the Palm Beach (FL) Daily News, and some Scripps Howard newspapers. interviewed regarding credit card debt matters, September 23, 2003.
The Denver Post, interviewed regarding banking economics and bank branching January 21, 2004.
Mortgage Lending Compliance Alert, interviewed regarding housing market outlook, economic and interest rate outlook, and lender profitability strategies. Feb. 2004.
CFA (Chartered Financial Analyst) Magazine, published by the Association for Investment Research, which recently became the CFA Institute. Interviewed by this professional certification organization that promulgates standards for investment professionals worldwide regarding business ethics and corporate governance issues. May 2004.
Continental magazine, interviewed regarding banking and its effect on economic resurgence, especially as it relates to Ireland. July 6, 2004.
European Business School, International University; Schlob Reichartshausen, Germany. Interviewed regarding intellectual property and business valuation techniques. July 24, 2004.
San Francisco (CA) Daily Journal, a legal newspaper, quoted regarding the alleged bank fraud and credit card fraud factors related to alleged Guantanamo Bay, Cuba, U.S. Air Force translator spy Ahmad Al Halabi, July 28, 2004.
Bank Tech & Security Newsletter, provided direction to a bank on the proper way to handle an attempted fraudulent international wire transfer. September 30, 2004.
Small Business Times, provided information concerning business valuation issues. September 30, 2004.
Mortgage Lending Compliance Alert, interviewed regarding the Bank Secrecy Act and Suspicious Activity Reports (SARs). October 12, 2004.
Mortgage Lending Compliance Alert, provided input for an article concerning compliance with the rules and regulations of lending. November 4, 2004.
Mortgage Lending Compliance Alert, provided input for an article on the Fair and Accurate Credit Transactions Act of 2003, a/k/a/ FACTA or FACT Act. Mar. 16, 2005.
Bank Technology & Security Alert, provided input for a question and answer section regarding online bill paying. April 11, 2005.
Mortgage Lending Compliance Alert, provided input for a question and answer section regarding closing costs for home mortgages. May 18, 2005.
Newark Star-Ledger newspaper, interviewed on the subjects of check cashing and the need for enhanced identification verification systems. May 26, 2005.
Bank Insurance & Securities Marketing Magazine, interviewed regarding ethical training considerations and the Securities & Exchange Commission's recently enacted Investment Adviser Code of Ethics. June 21, 2005.
Mortgage Lending Compliance Alert, provided input for an article regarding the legal, regulatory, and marketing considerations of providing lending services to Spanish speakers. June 21, 2005.
Bank Security & Technology, provided input for a question and answer section regarding bank facility security. August 11, 2005.
Bank Security & Technology Alert, provided input for an article regarding the security of bank computer systems. November 9, 2005.
Chicago Sun-Times, interviewed on bank marketing issues. January 9, 2006.
American Prospect Magazine, provided input for an article on business and banking ethics written by a reporter for the Philadelphia Daily News. February 1, 2006.
Bank Security & Technology Alert, provided input for a question and answer section regarding bank record retention. February 8, 2006.
Patent
On July 8, 2002, the United States Patent & Trademark Office registered a Provisional Patent to Don Coker for a business process for improving the prevention and detection of financial fraud involving personal and business checks, cashier's checks, postal and commercial money orders, letters of credit, bills of exchange, drafts, and many other types of financial instruments. In July 2003, the formal patent application was filed. This Patent was sold in early 2007.
Civic Activities
Katy School District (Houston suburb), Trustee, elective position.
U.S. Army Reserve, 1966-1968, Officer Training, Ft. Bragg, NC; Honorable Discharge.
Nottingham Country Civic Club, officer, 1,500 family neighborhood association.
Sunday School teacher, usher, host.
Education
University of Alabama, BA.
University of Alabama, post-graduate work.
University of Houston, post-graduate work.
Spring Hill College, AL, masters degree-level work.
Southern Methodist University, TX, executive education work.
Harvard Business School, MA.
Certificate in Business Valuation.
American Bankers Association - American Institute of Banking: financial statement analysis, business finance, bank investments, principles of bank operations, bank management, trusts.
National Institute of Real Estate Boards, commercial real estate finance.
International Council of Shopping Centers, shopping center finance.
National Hospital Association, one-week workshop in healthcare entity finance and valuation.
Mortgage Bankers Association, workshops in multi-family and SFR lending.
Federal Home Loan Bank of Dallas, training workshops on financial institution management, lending, investments, operations, et al.
Texas Savings & Loan Department, training workshops on financial institution management, lending, investments, operations, et al.
Federal Home Loan Mortgage Corp., real estate financing workshop.
First National Bank of Mobile, AL (now AmSouth Bancorporation), financial statement analysis, business finance, bank investments, credit card operations, deposit operations, bank management, trusts.
Gibraltar Savings Association (now Citigroup), commercial real estate finance, valuation, joint-ventures.
Citicorp, business, corporate, and real estate finance, valuation, deposit products, investments.
Southwest Bancshares (later Bank One, now JP Morgan Chase Bank), business finance and real estate investments.
Commercial Credit Corp. (now Citigroup), one-week Corporate Marketing Conference covering in-depth training in all financial products, plus 28 CDC Learning Center courses (45 semester hours) in business and economic subjects.
Frost Bank, advanced credit analysis and business finance.
Professional Background Summary
20+ years experience in management at banks, savings & loans, credit companies, mortgage banking companies, and a governmental financial institution regulatory agency. Positions held include Board of Directors member, Executive Vice President, Senior Vice President, Manager of Lending, Manager of Mortgage Banking, Regulatory Supervisory Agent tantamount to CEO). Committee memberships included Loan Committee, Executive Committee,
Audit Committee, and Pension Plan Trustee. Served as a corporate officer of various financial institution subsidiaries.
Management responsibilities included as many as 300 people in 22 locations nationwide in ten states and $1 billion in gross assets. Directly responsible for originating over 36,000 loans of all types totaling approximately $5 billion, and reviewing well over 100,000 financial statements and credit reports, and 25,000 appraisals.
Other Professional Activities
Consultant on various economic, valuation, real estate, marketing, and banking matters for clients in 45 states and several foreign countries.
Expert Witness, for plaintiff and defense, listed in the Association of Trial Lawyers of America's and the Defense Research Institute's databases of recommended consultants, plus state and local databases in AR, CO, DC, HI, IL, IA, LA, MN, MS, NY, NC, OH, PA, SD, WA, and San Francisco.
Phillips College, former Adjunct Professor of Business.
Institute of Financial Education, approved instructor for the educational arm of the U.S. League of Savings Institutions.
Prentice Hall Publishing, Simon & Schuster, Paramount Communications, technical editor and consultant on banking and real estate subjects.
Holiday Inn, Lender Advisory Panel.
Rodeway Inn, Lender Advisory Panel.
Novick's Money Market Seminars, panelist.
National Directory of Corporate Distress Specialists, approved management consultant.
Licensed Sports Agent, approved by the NCAA, Major League Baseball Players Association, and the AL Athlete Agents Regulatory Commission.
American Arbitration Association, approved Professional Commercial Arbitrator.
State of Texas Real Estate Commission, approved instructor and writer of courses.
Texas Real Estate Broker's License held for over ten years.
Recognition in Biographical Reference Books
Who's Who in America, 52nd - 56th eds.
Who's Who in the World, 12th - 16th eds.
Who's Who in Finance & Industry, 26th - 29th, 33rd eds.
Who's Who in Medicine & Healthcare, 1st - 3rd eds.
Who's Who in the South & Southwest, 21st - 33rd eds.
Directory of Distinguished Americans, 5th ed.
Who's Who Registry of Global Business Leaders, 1993 - 1994 ed.
Who's Who of Emerging Leaders of America, 3rd ed.
Who's Who Registry of Business Leaders, 1994 ed.
Personalities of America, 5th ed.
Personalities of the South, 14th ed.
Employment History
1986 - Present: Banking, Management & Economic Consultant in Atlanta, Georgia. Consulting and Expert Witness engagements covering all areas of banking, valuation, economics, real estate, international, management, finance, and business.
1985 - 1986: Executive Vice President, Manager of Lending & Board of Directors Member, Home Savings (now Citigroup), Houston, TX. Manager of all lending and mortgage banking. Number Two Executive. Heavily involved in investments and deposit activities. Officer of several subsidiary companies. Member of Loan Committee, Executive Committee, Audit Committee, et al.
1984 - 1985: Senior Vice President, Manager of Lending, First Federal Savings (now Guaranty Bank), San Antonio, TX. Manager of all lending and mortgage banking. Number Two Executive. Heavily involved in investments and deposit activities.
1983 - 1984: Southwest Regional Manager, Ford Motor Credit Corp., Houston, TX. Manager of commercial real estate finance, and some financing with dealers.
1977 - 1983: Regional Manager, Commercial Credit Company (now Citigroup), Houston, TX. Manager of commercial and residential real estate financing for the southwest, and involved in all financial products offered by the $7 billion company.
1974 - 1977: Manager of Commercial Real Estate Lending and Mortgage Banking, Southwest Bancshares (later Bank One, now JPMorgan Chase Bank), Houston, TX. Also involved in the origination and administration of construction loans, deposit and investment activities for lending clients including wealthy foreign nationals, corporate and personal lending, and credit card operations.
1973 - 1974: Assistant Regional Manager and Assistant Treasurer, Citicorp Real Estate, Houston, TX. Mortgage banking and construction lending for Citibank, N.A. (NY), and deposit and investment activities for wealthy foreign clients.
1972 - 1973: Loan Officer and Manager of Lending Department, Gibraltar Savings (now Bank of America), Houston, TX. At age 26, managed the day-to-day operations of Texas' largest S&L (55th largest in the U.S.). Handled construction and subdivision development loans, joint-ventures, and high-volume builder accounts.
1968 - 1972: First National Bank of Mobile (later AmSouth, now Regions Financial), Mobile, AL. Mortgage and real estate specialist in the Trust Department. Trained and worked in all areas of the bank including checking and savings, credit, corporate lending, personal lending, international, investments, trusts, credit cards, and funds transfers.
Mr. Coker can be contacted at:
423 Latimer Street
Woodstock, GA 30188-5052
Telephone: (770) 852-2286
Telecopiers: (973) 201-2534 or (419) 517-5284 or (610) 643-7870
E-mail: Bankexpert@cs.com
Key Words to Help Locate This Website:
credit card expiration date
credit card fraud
credit card receipts
FACT Act
FACTA
Fair Credit Reporting Act
Fair and Accurate Credit Transactions Act
Identity Theft
mask credit card expiration date
mask credit card number
truncation
truncation of credit card expiration date
truncation of credit card number
truncation of expiration dates
willful violation
15 USC 1681
15 USC 1681c
15 USC 1681c (g)
15 USC 1681c (n)
15 USC 1681n
Arizona credit card truncation, 44-1367
Arkansas credit card truncation, HB 1269
California credit card truncation, Civil-747
Colorado credit card truncation, HB 02-144
Delaware credit card truncation, SB 11
Florida credit card truncation, Bill No. 20, Bill # 20
Georgia credit card truncation, HB 213
Idaho credit card truncation, HB 134
Illinois credit card truncation, HB 259
Kansas credit card truncation, HB 2676
Kentucky credit card truncation, HB 70
Louisiana credit card truncation, Act 584
Maine credit card truncation, LD 1880
Maryland credit card truncation, SB 25
Michigan credit card truncation, Bill No. 5435, Bill # 5435
Minnesota credit card truncation, SB 506
Missouri credit card truncation, SB 292
Nebraska credit card truncation, HB 276
Nevada credit card truncation, SB 297
New Jersey credit card truncation, S 1149
New Mexico credit card truncation, SB 253
New York credit card truncation, A 5973
North Carolina credit card truncation, HB 357
North Dakota credit card truncation, SB 2037
Ohio credit card truncation, Bill No. 250, Bill # 250
Oklahoma credit card truncation, SB 931
Oregon credit card truncation, HB 2103
Previous Websites Included for Reference Purposes:
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http://firms.findlaw.com/CheckFraud/
http://firms.findlaw.com/BusinessValuation/
http://firms.findlaw.com/BusinessPlans/
http://home.talkcity.com/PresidioDr/bankexpert/DonCoker.html
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