June 2013

  • June 10, 2013

    June 2013 Legal Briefs

    Garnishment of Federal benefits rule revisions Consumer loan dollar amounts adjust July 1 The first California/Achieve financial settlement Breach of contract Final(?) ability to repay and qualified mortgage rules

May 2013

  • May 20, 2013

    May 2013 Legal Briefs

    Interagency statement on Biggert-Waters Flood Insurance CFPB ability to repay – QM clarification proposal Some tweaks for HDMA getting it right Escrow rule: What we should have said is … CARD Act rule revised NAME IT: A guide to formulating a formidable name for your bank Oklahoma’s Article 9 remains unchanged Oklahoma tax on IRA part 2:

  • May 3, 2013

    Cyber-fraud round up

    The FBI has recently begun issuing cyber alerts to keep our bankers apprised of potential cyber threats, including DDOS attacks. Our last OBA Fraud Alert was one and you will notice most are technical in nature and, ultimately, belong in the hands of those in charge of your network security. Be assured we (and the FBI) are also including outside service providers …

April 2013

  • April 28, 2013

    April 2013 Legal Briefs

    Traps for the Unwary FFIEC Social Media Guidance – Proposed A World of Two Names Extended Escrows Under Reg Z

  • April 25, 2013

    Info on DDoS attacks

    The FBI released a FBI Liaison Alert System (FLASH) Message today, containing information on recent DDoS attacks. The contents of the FLASH Message is listed below: SUMMARY (U) Since September 2012, US financial institutions have been under coordinated and timed DDoS attacks. In total, 50 U.S. financial institutions have been targeted in over 200 separate DDoS attacks with varying effects. …

March 2013

  • March 11, 2013

    March 2013 Legal Briefs

    ATR and QM Refinancing existing loans Safe harbors QM product features

  • March 7, 2013

    Regulatory Feedback Initiative

    The Regulatory Feedback Initiative (RFI) is an electronic, no-cost, anonymous survey bankers complete after each bank examination, whether a safey and soundness exam or a compliance exam. The idea behind its launch in 2011 is to create a data base that gives first-hand accounts of bank experience with bank regulatory agencies and identify “hot spots” in the field. This data, in …

February 2013

  • February 28, 2013

    Wire fraud reprise

    To draw your attention to our Fraud Alerts when they are critical, we only send them when an issue is of a critical nature. We also have never repeated alerts. However, the level of wire fraud attempted and completed has risen to a level that now requires some repetition. Look at the July 7, 2012 Alert on wire/ACH fraud and, again, revisit your policies and …

  • February 8, 2013

    February 2013 Legal Briefs

    The new mortgage servicing rules New appraisal rules Lending to the military – the CFPB’s new role

January 2013

  • January 16, 2013

    January 2013 Legal Briefs

    Out of state, tribal and CFR court orders ATM notice relief Hot topics for 2013 from the FRB COPPA update Deposit insurance reminder Remittance transfers: a brief reprieve Religious headgear and compliance