Legal

OBA’s Legal Department Introduces New Frequently Asked Questions Feature! Recent Case Sanctions Fraud Loss Shifting Provision in Commercial Deposit Account Agreements Compliance Dates Roundup

New CRA Regulation Effective 11/3/2010 Model Privacy Notices Safe-Harbor Under Reg P Will Change Effective 1/1/2011 New Final Rule Amends Reg Z, Prohibiting Certain Loan Originator Compensation and Steering Practices. Compliance Mandatory 4/1/2011 Federal Reserve Board Rule Reflects Delay in Gift Card Disclosure Requirements to 1/31/2011 Federal Reserve Board Announces Annual Indexing of Reserve Requirement Exemption Amount and Low Reserve Tranche …

Dodd-Frank Act Provides Changes to FDIC Insurance Coverage; TAG Program to Terminate 12/31/2010 Primer on Financial Privacy Issues Compliance with Risk-Based Pricing Final Rule Mandatory January 1, 2011 National Flood Insurance Program Extended through September 30, 2011 Compliance Dates Roundup

Final Guidance on Sound Incentive Compensation Policies Interim Rule Requires New Disclosures for Consumer Mortgage Loans; Compliance Deadline January 30, 2011 New TILA Requirement of Notice When Mortgage Has Been Sold or Transferred; Compliance Mandatory January 1, 2011 Department of Justice Final Rule on ADA Standards for Accessible Design and New Proposed Rules Will Affect Banks Compliance Dates Roundup

Final S.A.F.E. Act Rule Adopted School Warrants – A Primer Oklahoma H.B. 2936 Increases Fees for Compliance with State-Court Subpoenas Effective 11/1/2010 HOEPA Dollar Trigger Increased Effective 1/1/2011 Compliance Dates Roundup  

New Same-Day FedACH Service Available August 2, 2010 Avoiding Potential Pitfalls With Motor Vehicle Liens Oklahoma Department of Consumer Credit Updates Statutory Dollar Amounts Effective July 1, 2010 Regulators Issue Final Guidance on Correspondent Concentration Risks

Clarifications Made to Reg E Regarding Restrictions on Overdraft Charges on ATM and One-Time Debit Card Transactions Further Revisions to Reg E (Overdraft Protection) HIRE Act Provides Tax Incentives to Employers to Hire in 2010   FDIC Issues Guidance for Periods of Lapse of Flood Insurance Authority   Executive Order 13496 Requires Posting of Notice of Employees Right to Organize …

TAG Program Extended Through December 31, 2010 Mortgage Loan Officers Not Exempt Under FLSA According to New DOL Interpretation Banks’ Right of Setoff vs. Federal Exemption for Social Security and Other Exempt Federal Benefits – Which Wins? S.A.F.E. Act Update Compliance Dates Roundup

‘ABC’s of Handling Repossessed Property 2010 Provides Unique Opportunity to Defer Tax on Roth IRA Conversions Floor Plan Lending Presents Special Challenges (maybe from your regulator) When a Horse Is “Equipment” – It could only be the UCC Compliance Dates Roundup

Raffles and Giveaways and Lotteries, Oh My! What Can/Can’t a Bank Do? FACT Act Changes Mandatory July 1, 2010 (Reg V) Yet More Changes Affecting Open-End Credit to Consumers (Reg Z) Effective February 22, 2010 and July 1, 2010 Reminder: Escrow Required for HPMLs for All Applications Received after April 1, 2010 Compliance Dates Roundup