Publications Archive

by Rob Nichols For too long, banks with legitimate concerns about unbridled credit union growth have been portrayed as Goliath picking on David. The truth is that in many states, a credit union is one of the largest local financial institutions, outranking most of ...Read More

Question: We have a property that is partially in a flood zone. The house on the property is not in a flood zone, but the barn on the property is in a flood zone.  Do we have to require flood insurance for the barn?  ...Read More

Question: If we need to temporarily shut down one of our branches to treat for dangerous mold, do we need to give any kind of notice to our regulator?   Answer: At the federal level, there’s a specific exemption for temporary closings that are ...Read More

Question: I have a quick question related to Regulation D and reserve requirements. If we offer commercial escrow services to hold funds for two or more parties, are these funds held in escrow generally subject to Reg. D?   Answer: Yes, escrow funds are specifically included in the definition of ...Read More

Question: For examination purposes, should we be logging all changes to our website or just the ones related to compliance?   Answer: Since the bank’s website is generally considered an advertisement and sometimes contains disclosures required by federal regulations, the bank would want to ...Read More

By Jenny McCain In late April, the Board of Governors of the Federal Reserve System approved a notice of proposed rulemaking that would revise the Federal Reserve’s “control” rules under the Bank Holding Company Act of 1956 (Regulation Y). These rules that establish the ...Read More

The first line of last week’s Capitol Notes remains the same for this week’s edition: “The calendar giveth, and the calendar taketh away.”  But this time, the “calendar” in question is not the one that determines when the Legislature is or will be in ...Read More