In This Issue…
- From Adrian’s desk …
- Changes coming to counterfeit currency reporting
- CFPB releases FAQ on buy now, pay later products
- OBA education corner …
From Adrian’s desk …
By Adrian Beverage
OBA President & CEO
Just some random tidbits that might be of interest to our bankers this week!
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Just a quick post today as I’m with our group in Washington, D.C., visiting our regulators and legislators! Thus far, it’s been a resounding success as those who we’ve met with have been entirely impressed by the size of our contingent. They understand, when they see the dozens upon dozens walk into their offices, that bankers CARE about what happens on Capitol Hill, and are active politically.
This trip makes a difference.
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I dunno, but to me, it seems things are starting to drag a bit slower toward the election. Is this the equivalent of the dog days of summer in baseball?
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Remember, way back in the Aug. 26 OBA Update when I had my mic-drop moment and proclaimed “Nebraska stays undefeated deeper into the season than any of the Oklahoma schools.”?
Well, looks like that bet ended up being a push as all three teams lost this past weekend. Jeremy and Janis have been trying to point out that Nebraska actually lost on FRIDAY NIGHT, while OU and OSU lost on Saturday. I refuse to bring technicalities into this discussion, however.
Changes coming to counterfeit currency reporting
Effective Nov. 1, the U.S. Secret Service will no longer accept electronic submissions of suspected counterfeit notes via the USDollars website.
The Registration and Submission option will be removed and no longer available. Open electronic submissions entered prior to Nov. 1, will be available to previously registered users. After Nov. 1, USDollars will continue accepting bulk submissions from banks currently enrolled in the bulk submission process.
Effective Nov. 1, banks and other organizations must complete Secret Service Form 1604 and attach each suspected counterfeit note to the form. The completed SSF 1604 with the attached suspected counterfeit note should be mailed to the following address:
Bureau of Engraving and Printing
c/o Counterfeit Currency Processing Facility
Room 541-A
301 14th Street, SW
Washington, D.C. 20228
With the level of theft from the U.S. mail service, the OBA suggests the forms, with notes attached, be sent certified mail return receipt requested.
CFPB releases FAQ on buy now, pay later products
The Consumer Financial Protection Bureau released an FAQ last week about applying Truth in Lending regulation to buy now, pay later products.
The bureau issued in May an interpretive rule defining lenders who provide BNPL products as credit card providers under the Truth in Lending Act and its implementing regulation, Regulation Z. Among other things, the rule requires BNPL lenders to provide consumers with options currently available to credit card holders, such as the ability to dispute merchant charges through the creditor.
The FAQs provide guidance on applying Regulation Z to BNPL products, such as how to apply credit card periodic statement requirements to pay-in-four BNPL products that are accessed by digital user accounts, according to the CFPB.
OBA education corner …
Whoa. The difference between Saturday and Sunday was rather stark. One day, we’re sweltering while watching our favorite college football teams throw incomplete pass after incomplete pass, and then on the next day, we’ve got the windows open enjoyed the nice breeze. As they say in Oklahoma, don’t like the weather, just wait a few minutes! Don’t, however, wait too long to check out some upcoming continuing education opportunities available from the OBA!
- Loan Documentation 101: 2-Part Series, Oct. 1-2, webinar — Learn about basic secured loan documentation, lien perfection and business collateral in this two-part series.
- Understanding Commercial Real Estate Loan Documents, Oct. 2, webinar — Gain an understanding of all sections of required real estate loan documents.
- 2024 OBA Consumer Lending School, Oct. 7-11, Oklahoma City — The 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.
- OFAC Training for Customer Service Representatives, Oct. 8, webinar — Your staff is required to have training on OFAC. In this program, we will learn what the OFAC program is all about.
- Short-Term Loan Structuring for Commercial Borrowers – Getting That Line Of Credit Right, Oct. 8, webinar — This course is designed to demonstrate the factors required to consider in establishing the proper loan amount for short-term needs, and not rely solely upon a formula-driven approach.
- Overdraft Programs And Their Risk To Your Financial Institutions, Oct. 9, webinar — Overdraft services continue to be a target for regulatory scrutiny in 2024 and financial institutions who’ve been cited can attest to the damage unchecked fee income practices can have on an organization.
- 2024 BSA: AML/CFT Compliance Update, Oct. 22-Oklahoma City; Oct. 23-Tulsa — This program not only helps you stay ahead of current trends but also ensures you meet the annual training requirements mandated by BSA regulations.
- Bank Fraud Investigations 101 Seminar, Oct. 24, Oklahoma City — This class was designed to give you the processes and actions needed to successfully investigate a loss or potential loss event.
- 2024 IRA Basic and Advanced Issues, Basics: Nov. 5-Tulsa, Nov. 7-Oklahoma City; Advanced: Nov. 6-Tulsa, Nov. 8-Oklahoma City — The IRS has published final RMD regulations with a Jan. 1, 2025 effective date! The finalization of these highly anticipated regulations has a profound impact on IRA providers nationwide.
- 2024 OBA Operations School, Nov. 18-22, Oklahoma City — The Operations School is designed to prepare junior-level officers to mid-level operations managers to manage effectively and efficiently an operations function within a bank.
Also, take note the dates for the 2025 OBA schools have been set! Mark them down on your calendars and be ready for when registration opens for each!
2025 OBA banking schools
Intermediate School, Session I Feb. 3-7
Commercial Lending School March 2-7
Intermediate School, Session II June 2-6
Compliance School Aug. 18-22
Consumer Lending School Oct. 6-10
Operations School Nov. 17-21