Legal

Clarification from Federal Reserve Supports Viability of Short-Term Balloon Notes in Spite of HPML Changes  Reg GG Implementation Deadline Extended at Last Minute to June 1, 2010   Recent Reg CC Changes: We Are Quickly Heading Toward All Local Checks   Final Rule Revising Reg E Restricts Overdraft Charges on ATMs and One-Time Debit Card Transactions Effective July 1, 2010   …

Compliance with New Reg GG Is Mandatory on December 1, 2009 Oklahoma’s Estate Tax Repealed Effective January 1, 2010 3% Interest Requirement for County Deposits Gone Effective July 1, 2009 Change to Unclaimed Property Statute Effective November 1, 2009 OK to Charge Fee to Cash On-Us Check for Non-Customers?  

FDIC’s Final Rule Extends TAG Program 6 Months to June 30, 2010; Participating Entities Can Opt Out of Extension by November 2 Working Around the October 1 Reg Z Changes Changes to HUD’s Reg X (RESPA) Go In Effect January 1, 2010 Special Risks Surround Using Farm Products as Collateral

Creation of HPMLs and Requirements for Verification of Repayment Ability for HPMLs and HOEPA Loans New Escrow Requirement for HPMLs Effective for Applications Received on or after April 1, 2010 (October 1, 2010 for Manufactured Homes) Restrictions on Prepayment Penalties for HPMLs and HOEPA Loans Effective 10/1/2009 Revisions to HMDA (Reg C) Incorporate Reg Z’s Addition of HPMLs Effective 10/1/2009 …

Greetings from the OBA’s New General Counsel After the Loan: Don’t Lose Your Priority to a Federal Tax Lien   Credit Card Act of 2009: Certain Provisions Effective August 20, 2009, Plus Overview of Remaining Provision   Home Valuation Code of Conduct: Affects Sale of Residential Mortgage Loans to Fannie Mae and Freddie Mac Beginning May 1, 2009   New Notice Required Upon …

Reg D – Savings Deposit Transfers Rule Changes July 2, 2009 Reg Z – MDIA Changes – Effective July 30, 2009 The Secure and Fair Enforcement for Mortgage Licensing Act (S.A.F.E. Act) The Oklahoma Department of Consumer Credit’s Truth in Lending Permanent Rule Consumer Loan Dollar Amounts – No Changes  

Charging Consumer Interest Using a 360-Day Year? Adding a Floor to Variable-Rate Mortgage Loans? Waiving a Rate That is Too High Default Interest Not Allowed on Consumer Loans?  

New Rules for Disclosure of Overdraft Fees   1. Disclosing Total Fees Charged   2. Required “Tabular” Format   3. What Fees are Included   4. Disclosure of Account Balances   5. Making Other Choices?   6. Other Pending Proposals   Helping a Customer to Avoid or Decrease Overdraft Charges

Risk Management of Remote Deposit Capture

New FDIC Disclosure for Banks Offering Sweep Accounts