Closing accounts for the undesirable customer Military lending rules have teeth Closing accounts for the undesirable customer By Andy Zavoina Some language in this article may be considered offensive by some readers but is taken from the court documents and has not been “softened” to accurately portray the treatment some bank staff endured. The severity of the language may help …

Second round of stimulus payments Accepting OK Real ID receipts Special purpose credit programs BSA revisions Second round of stimulus payments By Pauli D. Loeffler With the first round of stimulus payments, customers who died prior to receipt were not eligible to receive them. This was made clear by on the IRS’s Economic Impact Payment Information Center website (https://www.irs.gov/coronavirus/economic-impact-payment-information-center) in …

Systemic overdraft problems Resolving escrow shortages and deficiencies An update on the Payday Lending Rule Systemic overdraft problems By Andy Zavoina Let’s talk “politically correct” and separate that from what is legally correct. The former term is used loosely to mean generally accepted by the vocal public, which in this case includes those tired of what they may view as …

FAQs on RESPA Section 8 The year is nearly over – Loose ends FAQs on RESPA Section 8 By Andy Zavoina When we hear “Section 8” and “RESPA” in the same sentence, violations and civil money penalties often come straight to mind. It promotes negative connotations much like hearing your dentist say, “root canal” or your accountant, “IRS” and “audit” …

Contracts for deed FAQ: Reg D early withdrawal penalties Flood program extended TRID timing requirement waivers SCRA is still in the news Contracts for deed By Pauli D. Loeffler What is a contract for deed? Title 16 O.S, §11A provides: All contracts for deed for purchase and sale of real property made for the purpose or with the intention of …

Advertise this way, everyone is doing it! Trust documents Advertise this way, everyone is doing it! By Andy Zavoina Penalties: In just over a month we heard of not one, two, or three cases of the Consumer Financial Protection Bureau (CFPB) enforcing advertising requirements on mortgage lenders, but four. Let’s cut to the chase for a recap of these enforcement …

Fair Lending—in the News and on Your Radar Fair lending and HMDA Fair lending and CRA Paycheck Protection Program Bank of America – disability Townstone – redlining Fair servicing The CFPB’s RFI Fair Lending—in the News and on Your Radar By Andy Zavoina It is not a huge surprise that enforcement actions have lessened from 2019 to 2020, but are …

Mortgage maturity date, 46 O.S. § 301 Appraisal update Reg E error claims and ‘unjust enrichment’ HMDA thresholds More on the death of savings transfer limits Mortgage maturity date, 46 O.S. § 301 By Pauli D. Loeffler One of the more frequently asked questions the OBA Legal and Compliance Team receives concerns when a Notice of Extension/Modification of Mortgage must …

Coronavirus Compliance Changes Changes in UCCC Amounts Effective 7/1/20 Coronavirus Compliance Changes By Andy Zavoina We are in a much different compliance environment than we were when the calendar went to 2020 – or are we? I want to highlight some recent rulings that have come down from the regulatory agencies so that you can see that the agencies are …

Work “after” the coronavirus Information on Oklahoma campaign accounts Are savings transfer limits dead? Work “after” the coronavirus By Andy Zavoina Whether you call it the new normal or the abnormal, as bankers we are really in new territory. Sometimes it is akin to walking into a dark room and feeling your way around and then learning someone is still …