Work “after” the coronavirus Information on Oklahoma campaign accounts Are savings transfer limits dead? Work “after” the coronavirus By Andy Zavoina Whether you call it the new normal or the abnormal, as bankers we are really in new territory. Sometimes it is akin to walking into a dark room and feeling your way around and then learning someone is still …
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April 2020 OBA Legal Briefs
Coronavirus and Assisting Customers Modify Policies—COVID-19 addendums Assisting borrowers New loans Loans past due or about to be Limits on fee, penalties and interest Regulatory reporting Credit bureau reporting Coronavirus and Assisting Customers By Andy Zavoina (with Pauli Loeffler) There is a risk balance that banks must follow so that in six months or at your next exam, you will …
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Corona virus and banking Management’s actions Update Education Resonsibilities Travel Security IT Vendors Military lending update Perfecting a security interest on a trailer Tax season information in Legal Briefs Coronavirus and banking By Andy Zavoina Let’s first set the stage for our discussion on the coronavirus. The coronavirus is a large family of viruses that range from the common cold …
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Index to Legal Briefs now online “Abusive” UDAAP Update – Policy Statement Compliance Aids – Policy Statement SECURE Act and IRAs LIBOR – Transition Plans HMDA Guides Index to Legal Briefs now online by Pauli Loeffler There are 15 years (January 2005-January 2020) of OBA Legal Briefs articles available on the OBA’s website. These articles are like an all-you-can-eat buffet …
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New Home Buyer Savings Account CFPB Supervisory Highlights UDAAP & GAP Credit cards Credit reporting (furnishing) New Home Buyer Savings Account By Mary Beth Guard I don’t recall what the last straw was with apartment living, but whatever it was spawned a very strong “we need to get our own house” feeling. I may or may not have painted the …
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These OREOs are no treat! Privacy: It’s for bank info, too Managing returns of duplicate payments These OREOs are no treat! By Andy Zavoina The Office of the Comptroller of the Currency (OCC) issued an enforcement order against Citibank, N.A. in October 2019 and imposed a $30 million civil money penalty because it violated the holding period allowed for the …
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Medical marijuana state question 788 and banking issues Editor’s note: This month’s Legal Briefs section has been ceded to one of the OBA’s strategic partners, McAfee & Taft, to allow their insight on medical marijuana and the resulting banking issues. As a disclaimer, however, the following does not necessarily reflect the views or advice of the OBA, its legal department …
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Residential appraisal threshold raised 2019 Oklahoma legislation Watch for new CTR filing instructions Residential appraisal threshold raised By John S. Burnett Agencies issue joint rule The Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency have adopted a final rule that increases the threshold for residential real estate transactions requiring an appraisal from …
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HEMP, CBD Do cashier’s checks expire? Mandatory vacation for bank employees Inform your borrower (Post-confirmation rate reduction) Two regulation amendments, two errors Hemp, CDB by Pauli Loeffler Hemp In April 2018, Oklahoma enacted legislation to permit cultivation of hemp under the federal Farm Bill of 2014 for research of hemp under pilot programs. In December 2018, the federal Agriculture Improvement …
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Amendments to Title 47 EGRRCPA Update – Part 2 Amendments to Title 47 By Pauli Loeffler Sell the vehicle, keep the license plate. Effective July 1, 2019, § 1112.2 was added to Title 47. If the borrower buys a new or used car or truck from a dealer, nothing has changed. If the borrower trades his car in for a …
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