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Higher Debt Allowed for $150-500 Million Holding Companies Some Advantages Permitted Debt Ratios Reason for the Change Additional Restrictions More New Changes to Regulation E Disclosure at ATM’s Preauthorized Debits Good Faith Errors Stop Payments Extended Time for Raising Errors Extent of Error Investigation Using Multiple CIP Approaches
March 2006
February 2006
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February 1, 2006
February 2006 Legal Briefs
Electronic Check Conversion under Regulation E Electronic Check Conversion Reg E Initial Disclosures Some Exceptions Check Conversion by Merchants Notice at POS Locations Notice for Billing Statements Coupon Books Authorization at POS Authorization on Billing Statements Comparison to ACH Rules Third Party Payment Advantages for Payees Disadvantages for Consumers?
January 2006
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January 1, 2006
January 2006 Legal Briefs
Fair Credit Regulation Restricts Use of Medical Information Background “Medical Information” Examples of Not Evaluating Credit Unsolicited Medical Information Financial Information Exception Permitted Gathering of Financial Information Proper Financial Use of Medical Information Improper Use of Medical Information Other Permitted Exceptions Proper Use of Exceptions Limits on Re-disclosure Affiliate Sharing
December 2005
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December 1, 2005
December 2005 Legal Briefs
Fed’s Warranty of Authorization for “Telephone Checks” Background Who Uses “Telephone Checks”? What Checks are Covered? Warranty of Authorization FTC Telemarketing Rule Interviewing the Customer Removing the “Midnight Deadline” Fraud and Errors Limitation on Returning Checks The OBA’s Involvement Homestead Exemption in Oklahoma Bankruptcies: What’s the Dollar Limit?
October 2005
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October 1, 2005
October 2005 Legal Briefs
Important Issues in Establishing Tragedy Accounts Using a Real Payee Endorsement Risk Tragedy Victim as Owner? Tax-Deductible Entity Setting up a Trust UTMA Account Risk-Based Approach Bank-Sponsored Account Guidelines for Residential Tract Development Loans Appraisal Methods Appraising Lots to be Developed Loan-to-Value Ratios Single-Unit Construction Loans Substituting/Releasing Collateral What is the Loan Amount? Commitment …
September 2005
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September 1, 2005
September 2005 Legal Briefs
Small Intermediate Banks and Changes in CRA Regulations Post-Closing “Real-Estate-Related” Fees are Finance Charges Banks Sharing Information about Former Employees More Details on Lottery Accounts Public Employees’ Payroll Deductions to Financial Institutions FDIC Statistics for Oklahoma
August 2005
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August 1, 2005
August 2005 Legal Briefs
The Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 Bankruptcy Chapter Eligibility for Consumers and Individuals a. Chapters and Restrictions b. Credit Counseling Notices Exemptions Statement of Intent, Redemption, and Reaffirmation Discharge Needs-Based Bankruptcy, Presumption of Abuse, Means Test The Automatic Stay
July 2005
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July 1, 2005
July 2005 Legal Briefs
“Four-Wheelers” Require Certificates of Title and Lien Entries Continuing Liens for Repair of Farm Equipment Mechanic’s Lien Provisions Changed for Motor Vehicles Changes in Items of Property Exempt in Bankruptcy Amendments to Family Wealth Preservation Act
June 2005
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June 1, 2005
June 2005 Legal Briefs
Consumer Loan Dollar Amounts Adjusting on July 1 a. Increased Late Fees b. “508B” and “508A” Loans c. Dealer Paper “No Deficiency” Amount Regulation DD’s Amendments Cover Overdraft Plans Background Expanded Emphasis of Disclosures Advertising “Free” Accounts General Advertising Requirements Misleading or Inaccurate Advertising Revised Truth-in-Savings Disclosures Periodic Statement Disclosures Itemizing Fees by Type
May 2005
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May 1, 2005
May 2005 Legal Briefs
Regulators Issue Guidance on Money Services Businesses Background Basic Due-Diligence Requirements for All MSB Accounts Performing Risk Assessments Risk Indicators Due Diligence for Higher-Risk Customers Suspicious Activity Reporting Review of Existing MSB Accounts Banks Not Regulators of MSB’s Guidance to MSB’s Guidance on the Final CIP Rule