Tuesday, December 5, 2023

Legal Briefs

October 2009 Legal Briefs

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

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September 2009 Legal Briefs

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

New Appraisal-Related Amendments Effective 10/1/2009

New Mortgage Servicing Practices Effective 10/1/2009

New Advertising Restrictions Affecting Closed-End Credit Loans Effective 10/1/2009

S.A.F.E. Act Redux

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August 2009 Legal Briefs

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 Sale/Transfer of Residential Home Mortgages & Protecting Tenants at Foreclosure Act, Both Effective May 20, 2009

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July 2009 Legal Briefs

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

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May 2009 Legal Briefs

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?

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April 2009 Legal Briefs

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

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January 2009 Legal Briefs

  1. Various Cost-of-Living Increases in Dollar Amounts for 2009
  2. No IRA Minimum Distributions Required for 2009
  3. Interagency Statement on Meeting Needs of Creditworthy Borrowers 

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December 2008 Legal Briefs

  1. Creditor Must Be Notified if Personal Representative Rejects a Claim in Probate
  2. Unclaimed Property—Collecting Fees Owed on Safe Deposit Boxes
  3. Oklahoma Adopts Uniform Real Property Electronic Recording Act
  4. Notification Required for Security Breach Of Computerized Data

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November 2008 Legal Briefs

  1. Capital Purchase Plan Deadline Extended for Non-publicly-traded Banks
  2. "Opt Out" Date Extended for FDIC’s Temporary Liquidity Program
  3. Tax Free Charitable Distributions from IRAs

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July 2008 Legal Briefs

  1. Commissioner’s Bill Revises Several Banking Provisions
  2. Recent Changes to Oklahoma Banking Board’s Regulations
  3. Major Changes to Oklahoma’s Record Retention Schedule
  4. Elder Abuse Punishment Increases

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