Legal Briefs

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 …

Systemic overdraft problems Resolving escrow shortages and deficiencies An update on the Payday Lending Rule Systemic overdraft problems By Andy Zavoina Let’s talk “politically correct” and separate that from what is legally correct. The former term is used loosely to mean generally accepted by the vocal public, which in this case includes those tired of what they may view as …

FAQs on RESPA Section 8 The year is nearly over – Loose ends FAQs on RESPA Section 8 By Andy Zavoina When we hear “Section 8” and “RESPA” in the same sentence, violations and civil money penalties often come straight to mind. It promotes negative connotations much like hearing your dentist say, “root canal” or your accountant, “IRS” and “audit” …

Contracts for deed FAQ: Reg D early withdrawal penalties Flood program extended TRID timing requirement waivers SCRA is still in the news Contracts for deed By Pauli D. Loeffler What is a contract for deed? Title 16 O.S, §11A provides: All contracts for deed for purchase and sale of real property made for the purpose or with the intention of …