Thursday, September 23, 2021

Week of Aug. 2

In This Issue…

Information about Advance Child Tax Credits deposits into closed accounts

The OBA’s compliance department wants banks to be aware the IRS started sending direct deposits of Advance Child Tax Credits on July 15, 2021. Additional ACTC credits will also be sent on Aug. 13, and the 15th of each month from September through December 2021.

Some of the direct deposits will be directed to accounts that have been closed by the depositor or the bank. This will probably mean that people in some banks will start thinking about “offsets.” But don’t go there!

Treasury regulations require that direct deposits of federal benefit payments directed to closed accounts be returned. The IRS will reissue the payments in check form. A bank cannot legally “reopen” a closed account to accept such a payment, and the payment cannot be diverted to recover on a charge-off. The payments should be returned even if the recipient has another account with your bank.

The IRS has an online tool – the Child Tax Credit Update Portal at https://www.irs.gov/credits-deductions/child-tax-credit-update-portal – for taxpayers to use to update bank account information.

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Tax commission seeks feedback on ELT system

Last session, the Oklahoma State Legislature passed SB 998, the Oklahoma Vehicle License and Registration Act.

The Oklahoma Tax Commission will be implementing and maintaining the ELT (Electronic Lien & Title) system.  Below, you will find a survey from the tax commission. It wants to gather information from all parties that would be using the system.  Please take a few minutes to complete the survey as your responses will help determine how the system is developed.

Click here to respond to the survey.

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OCC gives additional exam procedures for remittance transfers

The Office of the Comptroller of the Currency issued on Monday supplemental examination procedures on remittance transfers covered by Regulation E.

The supplemental procedures align the OCC’s supervisory approach with amendments to Reg E by the Consumer Financial Protection Bureau that took effect July 21, 2020.

The Reg E amendments permanently allow depository institutions to estimate certain fees and exchange rates when making disclosures to their customers about the cost of remittance transfers and increases the safe harbor threshold for identifying which banks are subject to the remittance rule’s requirements to 500 transactions.

The exam procedures apply to national banks and federal thrifts with assets of $10 billion or less. In addition to covering examination procedures for the amendments, the document also covers how examiners should determine whether a safe harbor exception applies.

You can click here to read the entire bulletin from the OCC.

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OBA Bankers’ Night Out programs ready for fall

The dates for the OBA Bankers’ Night Out programs have been finalized. Mark your calendar for the date of the program that’s in your area of the state and plan to attend.

Bring your coworkers with you so that everyone can be up to speed on the most recent developments affecting their job. In addition to state and federal legislative updates, the program will include a discussion on the recent developments in your industry.

As in the past, the schedule for each of these meetings is:

5:30 p.m. – Drinks
6:15 p.m. – Program
7 p.m. – Dinner

Registration will open soon. Locations and dates for this year’s events are:

  • Ardmore, Sept. 16.
  • Krebs, Sept. 23.
  • Tulsa, Oct. 12.
  • Oklahoma City, Oct. 26.
  • Woodward, Nov. 2.
  • Lawton, Nov. 4.

Please note: We will monitor the state’s COVID climate and send any necessary updates before each event.

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OBA education corner …

We’re officially into the dog days of August! It’s still almost a month until football season and 100-degree temperatures remain to be dodged. But the OBA education department can help you move through the dog days with its online and in-person offerings, including the following:

NOTE: Effective March 16, 2020, and until further notice, TTS (our webinar provider) has extended the OnDemand access period for all ‘Live Plus Five (Days)’ registrants to 60 days (versus five business days). Also, they are waiving the $75 per location fee for additional locations.

  • Protecting Your Salaried-Exempt Status, Aug. 12, webinar — A focus on only the new salary requirements can be a big mistake. One must also preserve and protect the salaried status once it has been properly established.
  • Servicemember Issues: The Military Lending Act & SCRA, Aug. 12, webinar — This webinar is designed to address all these issues, and especially the new MLA rules, so you can be prepared.
  • The Right of Setoff, Aug. 17, webinar — Do you know when the right of setoff is allowed and when it isn’t? Do you know if your financial institution has a statutory or contractual right of setoff? Do you understand the financial risks of using your setoff rights incorrectly?
  • Basic New Accounts Seminars, Aug. 18-Tulsa; Aug.19-Oklahoma City — This full-day workshop teaches essential new account opening procedures, best practices, and compliance requirements while focusing on vital identifying information for every new account type.
  • Opening Trust Accounts, Aug. 24, webinar — This webinar will cover standard trust-opening procedures and many “dos and don’ts” that arise as trusts and account holder situations change.
  • Cybersecurity Seminar, Sept. 21, Oklahoma City — This seminar is designed to provide training on evolving cybersecurity threats and what your bank should do to build a strong Information Security Program that helps protect against these threats.
  • 2021 Credit Analysis Basics, Sept. 23-Tulsa; Sept. 24-Oklahoma City — Attend this proactive seminar and learn how banks make lending decisions based on the five (5) C’s of credit- capacity, capital, collateral, conditions, and character!
  • 2021 OBA Consumer Lending School, Oct. 4-8, Oklahoma City — This program exposes students to major issues consumer credit managers face. It provides a framework for examining a bank’s consumer credit programs, policies and procedures.

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