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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
June 2005
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
April 2005
March 2005
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March 1, 2005
March 2005 Legal Briefs
Banking Agencies’ Joint Guidance on Overdraft Protection 1. Background 2. Safety and Soundness a. Account-Approval Standards b. Ongoing Monitoring c. Delinquencies and Charge-offs d. Call Report Treatment e. Vendors 3. Legal Risks a. FTC Act/Advertising b. TILA/Reg Z c. Equal Credit d. Truth in Savings …
February 2005
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February 1, 2005
February 2005 Legal Briefs
Explanation of Health Savings Accounts Background What is an HDHP? What’s the Advantage of an HDHP? What Are the Tax Advantages of an HSA? Establishing HSA’s at a Bank Special Limitations on HSA Contributions Qualifying Medical Expenses
January 2005
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January 1, 2005
January 2005 Legal Briefs
Guidelines on Security & Disposal of “Consumer Information” Broadened Emphasis What Information? Changes in Procedures and Contracts? Where to Find the New Provisions. Some Information-Protection and Information-Disposal Issues and Examples a. Directors’ Packets. b. E-mails and Files on a Computer c. Files and Other Paper Documents. Paying Deposits to Heirs Based on Small-Estate Affidavits