I recently read the brokered deposits FAQ from the FDIC and was a wee bit surprised to find out that I might be a deposit broker. In fact, there were several categories of persons that might surprise you as well.
Basel III (updated capital rule) requires banks to maintain capital based in part on the riskiness of the assets in their portfolios. To the extent more capital is required to support a transaction, that transaction is likely...more
I love the internet and the convenience of quickly searching through my friend, Google. You have probably done this too. You are out with friends and someone questions who won the World Series in 2001. It is fun to be able to...more
I was just reviewing the proposed CRA FAQs again (yes, that makes me a compliance nerd) and I was struck anew by the tension between lending programs that are designed for LMI markets and the requirements for safe and sound...more
My husband doesn’t like for me to admit it, but I am a registered Texas lobbyist. That means that I am on the list for every fundraiser for Texas candidates. And admittedly I do make contributions to business-friendly...more
Should non-obligors to a residential mortgage receive the early Truth in Lending Disclosures? -
Two months ago, I posed this question to the CFPB with my thinking that the answer should be “no.” Imagine my surprise when...more
Here’s a neat regulatory trick. Find a violation of a consumer reg and then conclude that the violation must also be unfair. Then you can increase the penalties.
Case in point: Reg E’s commentary clearly provides that a...more
Recently, the FDIC has identified a practice that it believes violates UDAP standards. Some bankers have looked at their integrated note/security agreement and observed that the collateral includes “other indebtedness”—which...more
In 2003, the Texas Constitution was amended to permit the issuance of interpretations relating to the home equity provisions of the Constitution. A lender acting in compliance with these interpretations would have a defense...more
DataTreasury Corporation (“DataTreasury”) has filed a new round of lawsuits against banks and their service providers relating to two patents which claims systems and methods for remotely capturing and centrally processing...more
Starting January 1, 2013, all commercial banks, savings institutions, credit unions, securities brokerages and insurance companies must report interest on deposits paid to nonresident alien individuals to the IRS and to the...more
Bankers received a Christmas present on December 20, 2012 when President Obama signed H.R. 4367, which eliminates the requirement for physical notices on ATMs regarding fees. That information is already disclosed onscreen,...more