Check your to do list By Pauli Loeffler Let’s review some of your annual compliance chores to ensure they are tidy and cared for. Security, Annual Report to the Board of Directors § 208.61 – The Bank Protection Act requires that your Security Officer report at least annually to the board of directors on the effectiveness of the security program. …

Vulnerable Adult Abuse, Neglect and Exploitation Report Perfection of security interest Lien entries on vehicles, manufactured Semi-trailers Purchase Money Security Interest, blanket filing Questions from our members Reg E LLC documentation Initial ARM notice Reconsideration of Value Questions (see also December 2024 Legal Briefs) By Pauli Loeffler Vulnerable Adult Abuse, Neglect and Exploitation Report In the September 2023 OBA Legal …

2024 Oklahoma Legislation – Part III (UCC) FAQs regarding account documentation 2024 Oklahoma Legislation – Part III Uniform Commercial Code Amendments By Pauli Loeffler Last legislative session saw the enactment of four Uniform Acts promulgated by the Uniform Law Commission (“ULC”), also known as the National Conference of Commissioners on Uniform State Laws. In the August OBA Legal briefs, I …

2024 Oklahoma Legislation – Part II More Deceased Customer Q&As 2024 Oklahoma Legislation – Part II Oklahoma Uniform Directed Trust Act of 2024 Oklahoma Trust Act (Amended) – Title 60 O.S. §§ 175.01 – 175.57 (Effective 11/1/2024) Registration and Pre-Registration – Transfer of License Plates – Contracts and Agreements for Electronic System – Title 47 O.S. § 1111.2 (Effective 9/1/2024) …

In this issue: 2024 Oklahoma Legislation – Part I A potpourri of deceased customer Q&As Still more on the FDIC’s revisions to part 328 2024 Oklahoma Legislation – Part I By Pauli D. Loeffler Uniform Special Deposits Act – Tit. 6 O.S. § 910 et seq. This is an entirely new Act that has only been adopted in the states …

More on the FDIC’s Revisions to Part 328 By John S. Burnett In last month’s Legal Update, I offered an analysis of the changes the FDIC has made to the rules applicable to deposit-accepting ATMs (and similar equipment) in its regulations at 12 CFR Part 328 on Advertisement of Membership, False Advertising, Misrepresentation of Insured Status, and Misuse of the …

Bankers’ FAQs Changes in UCCC amounts effective 7/1/24 ATMs and the FDIC’s new Advertisement of Membership Rule Bankers’ FAQs By Pauli Loeffler Some of the questions submitted to the OBA’s Compliance team are asked with some frequency by our members. We’ve gathered some of these questions and responses to assist you when similar situations present themselves. Altered check, indorsement claim …

Military Customers – A Protected Class? By Andy Zavoina For starters, service members are not a protected class under Reg B or ECOA, but note I added a question mark in the title of this article. The question is, do you want to treat them as a protected class? In my opinion, a bank often mitigates risks most effectively by …

Update on the new CRA regulations FDIC rule affects ATMs, websites, apps and more Personal liability Update on the new CRA regulations By John S. Burnett You know that the Federal Reserve Board, Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation announced final revisions to their Community Reinvestment Act regulations in October 2023, and those rules …

OBA Feedback FCRA and HR Employees, Social Media, and Ownership Federal Preemption in Question OBA Feedback By Andy Zavoina The OBA has had numerous requests about what can be done when a credit report is accessed on a consumer and that consumer becomes inundated with calls from other lenders competing for the loan or to offer ancillary services. The consumers …