FDCPA New stuff! Changes in UCCC amounts effective 7/1/19 CFPB’s Spring 2019 Regulatory Agenda FDCPA By Andy Zavoina The Fair Debt Collection Practices Act (FDCPA) is a new hot topic. I’ve already heard you thinking. “but that affects third party collectors and I’m collecting only debts owed to us, so it doesn’t apply.” But that may not be the case …

What to say and not say Dead beneficiaries Dead joint tenants Funds belong to an estate Watch your fees What to say or not say By Mary Beth Guard Last summer, while on a trip to Indiana, I got an “urgent” call forwarded from my home phone to my cell phone from a large money center bank that we had …

Complaints MLA SNAFU Convenience fees on loan payments Complaints By Andy Zavoina “We just don’t get complaints, we pride ourselves on customer service.” That may be true at some bank, perhaps one with a unicorn as a mascot, but I’ll wager most banks have customers who are unhappy about NSF and other account fees, being denied a loan, or a …

HMDA Reference Chart Flood Update HMDA Reference Chart by Andy Zavoina If your bank is a HMDA bank, congratulations, you’re a survivor and the 2018 Loan Application Register (LAR) is put to bed. I won’t mention that a first quarter review for 2019 is due in just a few weeks. In a helpful way, the Consumer Financial Protection Bureau (Bureau) …

TILA-RESPA FAQs Service member complaints Authorized signers 2nd Amendment Auditors TILA-RESPA FAQs By Andy Zavoina In early February 2019 the Consumer Financial Protection Bureau (Bureau) released four Frequently Asked Questions pertaining to integrated disclosures under Truth in Lending and the Real Estate Settlement Procedures Act (TILA-RESPA or TRID). It starts with the standard disclosure that there is no substitute for …

New year, new SAR Required year-end housekeeping FEMA NFIP snafu Residential appraisal threshold unchanged (yet) New year, new SAR By Andy Zavoina This time of the year many bankers are providing staff, management and their boards some annual updates and training. This may include security, Bank Secrecy Act and compliance topics. With recent events, one possible addition to what you …

IOLTA accounts SCRA – What not to do Privacy – Reg. P update Notes on beneficial ownership IOLTA accounts By Pauli Loeffler Since July 1, 2004, the Oklahoma Supreme Court has required all attorneys and law firms in Oklahoma to set up mandatory Interest on Lawyers’ Trust Accounts (IOLTAs) with interest payable to the Oklahoma Bar Foundation, with a few …

Revocable trusts deposit insurance Complaints update The loan estimate and “no cost” loans Revocable trusts deposit insurance By Pauli Loeffler A bit over a decade ago, the FDIC made changes to its deposit insurance coverage for trusts. Charles Cheatham wrote about the changes for the October 2008 OBA Legal Briefs, and there have really been no changes since then. However, …

UTMA accounts Loans to minors SCRA update FCRA credit freeze update UTMA accounts By Pauli Loeffler In the September 2018 OBA Legal Briefs, I wrote about deposit accounts that can be opened for a minor as owner or co-owner. This month, we look at the other important account offering for minors, accounts opened under the Oklahoma Uniform Transfer to Minors …

Deposit accounts for minors HMDA filing update for small reporters Deposit accounts for minors By Pauli D. Loeffler We get a lot of emails and calls regarding minors as owners on accounts and UTMAs. There are various OBA Legal Briefs articles covering aspects of these accounts in piecemeal fashion, but some of them are not easy to locate, and there …