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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 …
December 2009
November 2009
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November 10, 2009
November 2009 Legal Briefs
Compliance with New Reg GG Is Mandatory on December 1, 2009 Oklahoma’s Estate Tax Repealed Effective January 1, 2010 3% Interest Requirement for County Deposits Gone Effective July 1, 2009 Change to Unclaimed Property Statute Effective November 1,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?
October 2009
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October 15, 2009
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
September 2009
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September 11, 2009
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 …
August 2009
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August 7, 2009
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 …
July 2009
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July 9, 2009
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
May 2009
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May 19, 2009
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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May 4, 2009
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