Legal Briefs

September 2026 The FFIEC’s Proposed Revisions to the CAMELS Rating System For nearly thirty years, the Uniform Financial Institutions Rating System (UFIRS)—commonly known as the CAMELS rating system—has served as the ultimate report card for U.S. banks. As most of you already know, it grades institutions across six areas— Capital adequacy, Asset quality, Management, Earnings, Liquidity, and Sensitivity to market …

August 2026 Banker Q&As by Pauli Loeffler HMDA reportable as a refi, or not reportable since it is now a construction loan. We made a loan to purchase (then sale) an investment 1 unit dwelling.  On that same loan we had additional collateral on a 1 unit dwelling that was also being sold.  The borrower tore down the purchased dwelling …

June 2026   The “Authorized” Fraud Dilemma in Real Time Payments Update to May Article re: Interim Final Order By Scott Thompson   Changes in UCCC amounts effective 7/1/26 By Pauli Loeffler   The “Authorized” Fraud Dilemma in Real-Time Payments For decades, the legal relationship between a community bank and its depositor regarding fraud was governed by a relatively stable …

“I received a garnishment…” By Pauli D. Loeffler Receipt of a garnishment summons means the bank is potentially liable: a) to the customer if it freezes funds when it shouldn’t or b) to the creditor if it fails to freeze funds when it should. For that reason, I get a lot of calls and emails regarding garnishments, and it seems …

April 2026 OBA Legal Briefs By Scott Thompson First in Time, First in Right? Lien Priority Disputes Between Lenders and M&M Lienholders Introduction For commercial lenders in Oklahoma, few words induce as much anxiety as “mechanic’s lien.” In the complex world of construction financing, the security of a bank’s mortgage is paramount. A lender generally assumes that by recording a …

LEGAL update   643 N.E. 41st Oklahoma City, OK 73105 Phone: 405-424-5252 Toll free: 866-424-5252 Fax: 405-424-4518 compliance@oba.com www.oba.com   WE MAKE BANKERS BETTER March 2026       “We received guardianship documents…” By Pauli D. Loeffler First things first Where are the Oklahoma guardianship statutes? Unless indicated otherwise in this article, citations are to Title 30 of the Oklahoma …

February 2026     The Uniform Mortgage Modification Act By Scott Thompson The Uniform Mortgage Modification Act (UMMA), approved by the Uniform Law Commission (ULC) in 2024, represents a significant attempt in modernizing real estate backed financing. Designed to bring clarity and predictability to the process of modifying both residential and commercial mortgages, the Act provides a vital “safe harbor” …

GAO’s Green Book has been updated effective fiscal year 2026 The Judicial Erosion of Federal Preemption: National Association of Industrial Bankers v. Weiser and the DIDMCA Opt-Out The OBBBA Auto Interest Provisions GAO’s Green Book has been updated effective fiscal year 2026 By Pauli Loeffler Standards for Internal Control in the Federal Government—known as the Green Book—sets the standards for …

Pennies By Pauli Loeffler I have gotten numerous questions from bankers regarding guidance as these coins will be phased out.  I had one banker tell me that she had heard that “rounding” down was not acceptable.  When I asked the source of this information, she had received it by word of mouth. I found nothing to support this assertion and …

The GENIUS 0Act and the Stable Coin ERA Oklahoma’s corporations law Consumer Credit Code (“U3C”) Surcharges The GENIUS ACT and the Stable Coin ERA By Scott Thompson The passage of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) represents a potential defining moment for the traditional American financial system. This landmark legislation has officially brought stablecoins—digital …