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 …

CFPB Proposes New NSF Fee Rule Overdrafts — Comments Requested Editor’s Note: We do not usually write about proposed rules in Legal Briefs because so much can change between publication of a proposal and issuance of a final rule. However, we believe that Oklahoma’s bankers need to know about both of the recent CFPB proposals discussed in this edition. CFPB …

’Tis Still the Season — Security and Fraud Losses MLOs Hirable Now — Changes in Section 19 AI in Banking ’Tis Still the Season By Andy Zavoina Security and Fraud Losses The holiday season has ended and now it is all about the returns. Side note – it is a great time not to be working at Amazon. What does …

Year End, Year Start Year-End, Year Start By Andy Zavoina This is a time of celebrations, family, and looking forward to a new beginning as the calendar turns to 2024. But, has every “i” been dotted and “t” crossed for 2023? Do you get to exhale in a sigh of relief as you enjoy the holiday season, chill for a …

Loans, ECOA, and Noncitizen Discrimination New CRA Final Rule Released Loans, ECOA, and Noncitizen Discrimination By Andy Zavoina To me, this is one of those statements that says it is a warning shot and you need to know where the bullet may drop. This is your opportunity to evaluate the situation and step to the side to avoid injury, if …

Deposit account questions and answers Other frequently asked questions The OBA Compliance Team fields well over a hundred email messages every month, along with a healthy number of telephone inquiries. This month, our Legal Briefs include a sampling of the emails, which have been anonymized to remove the names of banks and individuals. Deposit account questions and answers. Compiled by …

OK Legislation 2023 By Pauli D. Loeffler Oklahoma Uniform Consumer Credit Code Title 14A Sec. 1-106 of the Oklahoma Uniform Consumer Credit Code  in Title 14A (the “U3C”) is the section that determines when and how much dollar limits under Title 14A are subject to change. These changes are based on increases in the Consumer Price Index for Urban Wage …