Legal Briefs

Don’t ignore the FDCPA regulation coming November 30 (Part 1) New Stuff on Legal Links Don’t ignore the FDCPA regulations By John S. Burnett The Consumer Financial Protection Bureau’s revisions to Regulation F become effective on November 30, 2021, less than a month from now. While on their face the rules in Reg F will apply to debt collectors who …

Regulatory priorities Consumer complaints 2021 OK legislation—Part III OK Banking Code Judgment liens Motor Vehicles OK Tax Code OK POA Act—Part II Uniform Consumer Credit Code (“U3C”) § 3-508A Uniform Interstate Depositions and Discovery Act of 2021   Regulatory Priorities By Andy Zavoina You spend your days preparing for meetings, going to meetings, auditing your bank for various compliance topics, …

Reg Z’s business day definitions Advance Child Tax Credits and closed accounts 2021 Oklahoma legislation—Part I Reg Z’s business day definitions By John S. Burnett Why Juneteenth caught lenders unprepared Congress clearly doesn’t know (or care?) that two days’ notice isn’t enough to give lenders when they pass legislation creating a new federal legal public holiday. The kerfuffle that erupted …

Vacations — Required or recommended Vacations – Required or recommended By Andy Zavoina We last wrote about vacation time in the September 2019 Legal Briefs. That was a short article on the recommended necessity of taking consecutive days off. After a year of COVID-19 and everyone being couped up, summer 2021 stands to be a record as people can finally …

CFPB to mortgage servicers: “Hear us NOW” Changes in UCCC amounts effective July 1, 2021 CFPB to mortgage servicers: “Hear us NOW” By Andy Zavoina The Consumer Financial Protection Bureau issued Bulletin 2021-02 on April 1, 2021. This was no April Fools’ joke, because the bulletin is entitled “Supervision and Enforcement Priorities Regarding Housing Insecurity.” I focus on the words …

Dot your i’s, cross your t’s (employer workplace notice rules) Foreclosures and evictions after a pandemic Dot your i’s, cross your t’s By Andy Zavoina We, in the compliance and legal fields make it a habit of dotting our i’s and crossing out t’s because we are nitpickers. We look for little details and we agonize over potential terms like …

Third round of stimulus payments (EIP3) Reg B has expanded: What you need to do UDAAP U-turn More reasons to watch the Bureau Third round of stimulus payments (EIP3) By Pauli D. Loeffler Basics. To receive the third stimulus payment (“IEP3”) the payee(s) must be U.S. citizens or U.S. resident aliens. The payee must have a social security number issued …

Happy Anniversary! It’s 2020.1! (COVID-19 workplace and vaccination policies) Inquiring about disability and medical exams Confidentiality New hires Reasonable accommodations Discrimination in the workplace Vaccinations Happy Anniversary! It’s 2020.1! (COVID-19 workplace and vaccination policies) By Andy Zavoina It was just about a year ago that we all became even more intimately familiar with what the term “pandemic” really meant to …

Closing accounts for the undesirable customer Military lending rules have teeth Closing accounts for the undesirable customer By Andy Zavoina Some language in this article may be considered offensive by some readers but is taken from the court documents and has not been “softened” to accurately portray the treatment some bank staff endured. The severity of the language may help …

Second round of stimulus payments Accepting OK Real ID receipts Special purpose credit programs BSA revisions Second round of stimulus payments By Pauli D. Loeffler With the first round of stimulus payments, customers who died prior to receipt were not eligible to receive them. This was made clear by on the IRS’s Economic Impact Payment Information Center website (https://www.irs.gov/coronavirus/economic-impact-payment-information-center) in …