Clarification from Federal Reserve Supports Viability of Short-Term Balloon Notes in Spite of HPML Changes 

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Compliance with New Reg GG Is Mandatory on December 1, 2009

Oklahoma’s Estate Tax Repealed Effective January 1, 2010

3% Interest Requirement for County Deposits Gone Effective July 1, 2009

Change to Unclaimed Property Statute Effective November 1, 2009

OK to Charge Fee to Cash On-Us Check for Non-Customers?
 

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FDIC’s Final Rule Extends TAG Program 6 Months to June 30, 2010; Participating Entities Can Opt Out of Extension by November 2

Working Around the October 1 Reg Z Changes

Changes to HUD’s Reg X (RESPA) Go In Effect January 1, 2010

Special Risks Surround Using Farm Products as Collateral

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Creation of HPMLs and Requirements for Verification of Repayment Ability for HPMLs and HOEPA Loans

New Escrow Requirement for HPMLs Effective for Applications Received on or after April 1, 2010 (October 1, 2010 for Manufactured Homes)

Restrictions on Prepayment Penalties for HPMLs and HOEPA Loans Effective 10/1/2009

Revisions to HMDA (Reg C) Incorporate Reg Z’s Addition of HPMLs Effective 10/1/2009

New Appraisal-Related Amendments Effective 10/1/2009

New Mortgage Servicing Practices Effective 10/1/2009

New Advertising Restrictions Affecting Closed-End Credit Loans Effective 10/1/2009

S.A.F.E. Act Redux
 

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Greetings from the OBA’s New General Counsel

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Reg D – Savings Deposit Transfers Rule Changes July 2, 2009

Reg Z – MDIA Changes – Effective July 30, 2009

The Secure and Fair Enforcement for Mortgage Licensing Act (S.A.F.E. Act)

The Oklahoma Department of Consumer Credit’s Truth in Lending Permanent Rule

Consumer Loan Dollar Amounts – No Changes
 

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Charging Consumer Interest Using a 360-Day Year?

Adding a Floor to Variable-Rate Mortgage Loans?

Waiving a Rate That is Too High

Default Interest Not Allowed on Consumer Loans?
 

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New Rules for Disclosure of Overdraft Fees

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New FDIC Disclosure for Banks Offering Sweep Accounts
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1. Various Cost-of-Living Increases in Dollar Amounts for 2009
2. No IRA Minimum Distributions Required for 2009
3. Interagency Statement on Meeting Needs of Creditworthy Borrowers 

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1. Creditor Must Be Notified if Personal Representative Rejects a Claim in Probate
2. Unclaimed Property—Collecting Fees Owed on Safe Deposit Boxes
3. Oklahoma Adopts Uniform Real Property Electronic Recording Act
4. Notification Required for Security Breach Of Computerized Data

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1. Capital Purchase Plan Deadline Extended for Non-publicly-traded Banks
2. "Opt Out" Date Extended for FDIC’s Temporary Liquidity Program
3. Tax Free Charitable Distributions from IRAs

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1. Recent Changes to FDIC Insurance for Trusts, POD Accounts
2. Importance of Training to Deal with FDIC Insurance Questions

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1. Two Changes to Servicemembers’ Civil Relief Act
2. Tax Credit for First-Time Homebuyers
3. Can Banks Freeze Home-Equity Lines of Credit?

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