Tuesday, December 7, 2021

Week of Nov. 1

In This Issue…

OBA dues invoices being sent this week

The annual dues invoices from the OBA are being sent to all our member banks this week.

Strategic member dues invoices are also being mailed.

If any of our banks have questions about their invoices, or would like more information, please feel free to contact our CFO, Lea Ann Jackson, at 405-424-5252 or leaann@oba.com.

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2022 Reg. Z dollar thresholds announced

The CFPB recently announced 2022 changes in dollar thresholds for several Regulation Z provisions governed by the CARD Act, the Home Ownership and Equity Protection Act and the Dodd-Frank Act.

The thresholds are based on changes in the Consumer Price Index and take effect on Jan. 1, 2022.

For credit cards, the penalty fees safe harbor for 2022 increased to $30 for a first late payment. The subsequent late payment safe harbor fee also increased to $41. The minimum interest charge disclosure threshold will remain unchanged for 2022 at $1. The loan amount at which HOEPA’s points-and-fees test comes into effect will increase to $22,969, and the HOEPA points-and-fees trigger will rise to $1,148.

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CFPB issues guidance to assist with Reg. F compliance

The CFPB has recently released several guidance documents on validation notices that are intended to facilitate compliance with requirements in the Regulation F debt collection final rules.

The rules will take effect on Nov. 30. The Fair Debt Collection Practices Act, upon which Regulation F is based, does not generally apply to creditors collecting their own debts and thus does not generally apply to banks; however, banks routinely oversee the activity of third-party collectors.

You can read more about these rules, and also download helpful FAQ and other documents, from the ABA Banking Journal by clicking here.

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OBA education corner …

November is here, which means Thanksgiving is closing in! Turkey, pumpkin pie, mashed potatoes, pumpkin pie, dressing, pumpkin pie … it’s one of our favorite holidays here at the OBA! But don’t let it distract you from all the upcoming education opportunities we have to offer, 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.

  • Checks — Endorsements, Fraud and Compliance IssuesNov. 9, webinar — This program will look at who has the right to endorse the back of a check, and where is proper endorsement placement. We’ll also look at what happens if a check is not endorsed properly, when it may be best not to accept the check at all due to missing or problem endorsements, why we do not put business checks into personal accounts and why we do not give less cash on business accounts.
  • Lending 101 Compliance, Nov. 15, webinar — In this unique webinar, Anne Lolley will provide an overview of federal compliance laws. This is a great training tool for newer lenders and processors, and the webinar will help even experienced bankers understand the source of the various requirements.
  • Regulation O, Nov. 17, webinar — Typical violations include illegal overdrafts to insiders or extensions of credit that exceed one of several lending limit provisions contained in the regulation. These violations generally result from a lack of adequate procedures. Simple steps to monitor overdrafts and total extensions of credit to insiders are usually sufficient to prevent such violations. This program provides suggestions for procedures.
  • Most Common TRID Issues, Nov. 18, webinar — In this webinar we’ll explore those hot spots, gray areas, and frequently-violated provisions. We’ll spend time discussing the timing of the various disclosures (which can get quite complicated), disclosure of fees, and calculating tolerances and potential reimbursement issues. Our goal is to ensure you understand where the TRID rules can create uncertainty and risk, and insulate your institution as much as possible from noncompliance.
  • Compliance Responsibilities in Foreclosures – What Are The Expectations Now?, Nov. 19, webinar — This webinar will discuss requirements and provide guidance on the proper steps to follow to ensure you understand all the requirements when considering or initiating a foreclosure action.
  • Employment Records And How To Keep Them, Nov. 19, webinar — This program provides information not just on what records you should keep and for how long, but on the several underlying and even more important issues of record creation, storage and the DON’TS that create the major liabilities.
  • Key Ratio Analysis seminars, Dec. 1-Tulsa; Dec. 2-Oklahoma CityAttend this proactive seminar and learn a “five-step” analysis plan to calculate the key ratios covering liquidity, activity, leverage, operating performance and cash flow analysis and correctly interpret the financial condition of the business client.

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