Publications Archive

Question: If the bank does not use any type of credit report when denying deposit accounts, are we required to provide an adverse action notice? Answer: If the bank did not use any type of credit report to deny the deposit account application, then ...Read More

The Legislature passed the halfway point of the 2022 Regular Session last week, finishing days 16,17, and 18 of the 30-day session. Lawmakers are expected to continue meeting three days per week for the foreseeable future, which could potentially lead to an early sine ...Read More

Q. We have a publicly traded company that wants to open a checking account. I believe the company would be excluded from the beneficial ownership information, but would we still have to collect information for a controlling person? A. If the customer is a publicly traded ...Read More

QUESTION: Do we have to disclose the loan officer’s NMLS ID on the promissory note for a HELOC? ANSWER: While Regulation Z does have a specific requirement to include the NMLS ID on the promissory note, it excludes open-end credit which would include a ...Read More

QUESTION: What is the current closed-end threshold for partial exemptions?  When does it change? ANSWER: The partial exemption closed-end threshold is currently 500 transactions in each of the two previous years and is not currently scheduled to change.  There is currently a full reporting ...Read More

The Special Session called by Gov. Kay Ivey concluded last Thursday, as the Legislature gave final approval of a bipartisan plan to invest some $772 million in American Rescue Plan Act (“ARPA”) funds. The $772 million comes as part of Alabama’s $1.1 billion initial ...Read More

Gov. Kay Ivey put the 2022 Regular Legislative Session on hold last week by calling a special session to prioritize the allocation of federal COVID relief funds received from the American Rescue Plan Act (“ARPA”). Legislators are working to determine how best to invest ...Read More