Posts filed under ‘Federal Legislation’

Are You In Compliance With The Durbin Amendment?

For an industry of debit card issuers the Durbin amendment is like a bad back; you can learn to live with it but there is always enough chronic pain to remind you that there is something a little off. So it is that once again the Amendment is back in the news and once again large debit card issuers and Visa are in the crosshairs of merchants and the Department of Justice: Here is why.

The Durbin amendment had two major components: First, it capped the interchange fees that financial institutions with $10B or more in assets could charge the merchants; secondly it required that all debit card issuers give merchants the ability to process payments through two unaffiliated networks (e.g. Visa and NYCE).  

The problem is that the system was designed in the ancient times of a decade ago when only futurists were talking about online shopping doing away with retail.  PIN based authentication to trigger Point-Of-Sale transactions has long been an industry standard.  However, PIN based authorization is of course not an option for the wine sipping, sweatpants wearing consumer buying toiletries online on a Friday night.  Networks such as NYCE can now process such transactions but critics argue that large issuers and the Visa networks have been slow to turn on these updated systems.  As explained in this blog “…there is a fundamental issue with Bank Identification Number (BIN) enablement, preventing the growth of PINless. In a nutshell, many issuers are not switching on PINless functionality when they issue bank cards, which means merchants are unable to use it for a large proportion of transactions. In our experience, a merchant is unlikely to be able to use PINless more than 50% of the time.”

Not surprisingly, this complaint has gotten the attention of Senator Durbin and Congressman Welch  who wrote this letter to the Federal Reserve urging it to take a look at whether large issuers and Visa are violating Durbin.

Of course, the Durbin amendment is only relevant to the extent that a transaction involves a debit card.  There are now FinTechs that specialize in scraping up a consumer’s financial information—with their permission— and allowing them to quickly provide this information to a wide range of businesses such as financial planners.  One of the leading companies in this area is Plaid.  Plaid has an ingenious business model in which it will allow consumers to replace debit card transactions with ACH payments.  It has a growing network of merchants who are willing to accept the occasional ACH transaction from individual consumers.  Suffice it to say, ACH transactions are a lot cheaper for merchants than are interchange fees.  Visa decided it was worth buying Plaid for $5B.  DOJ moved to block the deal and with the case on the verge of going to trial last summer, Visa and Plaid decided it was best to leave each other at the altar. 

The scrutiny is increasing.  The WSJ was one of several papers reporting on Friday that Visa is being investigated over its debit card practices.  With Senate democrats in control of hearing agendas, brace yourself for another round of payment processing investigations as merchants once again claim to be victimized by the debit card processing system.   Cue the violins.

March 22, 2021 at 10:00 am Leave a comment

There’s a New Old Sheriff in Town

In its latest step to underscore just how aggressively it intends to regulate consumer banking and products, the CFPB issued a statement rescinding an order issued by the CFPB in the waning days of the Trump administration which critics argued limited its ability to sue companies for abusive practices.  Normally, there is nothing noteworthy about an agency’s new leadership rescinding regulations put in place by an agency led by a different party, but the CFPB’s action impacts how it is going to use one of its biggest weapons in its regulatory arsenal. 

12 USCA § 5536 gives the CFPB its key civil enforcement powers.  Under the Dodd-Frank Act, it is unlawful for entities subject to CFPB’s jurisdiction

  • to offer or provide to a consumer any financial product or service not in conformity with Federal consumer financial law, or otherwise commit any act or omission in violation of a Federal consumer financial law; or
  • to engage in any unfair, deceptive, or abusive act or practice;

State laws had long given attorneys generals, and in states like New York, private parties the right to sue financial service providers for engaging in Unfair and Deceptive Acts and Practices (UDAP).  In addition, the Federal Trade Commission has had the right to exercise similar powers for decades.  This traditional language wasn’t enough for Congress.  So when it drafted subdivision B, it added abusive to the list of potential wrongs. 

As readers of this blog know, every word matters and in extending the traditional UDAP powers to include abusive conduct, many a lawyer, and the occasional law professor were perplexed.  In fact, several lawsuits challenge the new standard as so vague that it did not give people adequate notice of what constituted illegal conduct.  The Bureau has beaten back these challenges [CFPB v. All Am. Check Cashing, Inc., No. 16-cv-356, 2018 WL 9812125, at *3 (S.D. Miss. Mar. 21, 2018)].  Since 2011 it has brought 32 enforcement actions that have had an abusiveness and unfairness claim but only two of those were predicated solely on abusiveness.

With these statistics in mind, reasonable people asked if an abusiveness standard could really be distinguished from an act which is deceptive and unfair? After all, in testimony before Congress Director Richard Cordray explained “[W]e have determined that [the definition of ‘abusive’] is going to have to be a fact and circumstances issue; it is not something we are likely to be able to define in the abstract. Probably not useful to try to define a term like that in the abstract.”  While I admire the director’s honesty, this is hardly the type of statement that companies investing millions of dollars in complying with a new set of highly nuanced regulations wants to hear. 

Which brings us to the reason for today’s blog.  As one of her last acts, Director Kathy Kraninger issued a policy statement explaining that the bureau had to do a better job of explaining when conduct was abusive.  The statement explained that it would also not penalize good faith attempts to comply with the standard and most importantly would not use abusiveness as the sole criteria for a civil action. 

In repealing this statement, the bureau announced yet again that like Reggie Hammond in the classic movie 48 Hours, there’s a new sheriff in town.  He’s not going to unilaterally take any of his enforcement powers off the table. 

“In particular, the policy of declining to seek certain types of monetary relief for abusive acts or 10 85 FR at 6735-36. 11 12 U.S.C. 5511(b)(2). 5 practices—specifically civil money penalties and disgorgement—is contrary to the Bureau’s current priority of achieving general deterrence through penalties and other monetary remedies and of compensating victims for harm caused by violations of the Federal consumer financial laws through the Bureau’s Civil Penalty Fund. Likewise, adhering to a policy that disfavors citing or alleging conduct as abusive when that conduct is also unfair or deceptive is contrary” to Congressional intent. 

Suffice it to say, regulation by enforcement is back with a vengeance.  Make sure you pay attention to the Bureau’s enforcement actions and the legal rationale underpinning their decisions. 

March 17, 2021 at 10:29 am Leave a comment

Does Your Deposit Agreement Contain an Arbitration Clause?

If your answer to that question is no, then my next question is why not?  Let’s face it, the world is changing.  Members are more willing to sue you than they were just 15 years ago; more lawyers have become skilled at cost effectively bringing class action lawsuits over alleged violations of consumer banking orders; and, as credit unions grow, they also become bigger litigation targets.

In many ways, now is an ideal time to be considering the issue.  The law now firmly establishes the right of credit unions and banks to include arbitration provisions in their account agreements.  For instance, just last week a court upheld the legality of a credit union’s amendment to its deposit agreement stipulating that members agree to arbitrate disputes arising under the agreement and to waive participation in class action lawsuits.  The credit union’s victory reflects increasingly settled law in this area.  I just popped in the words arbitration agreement/class action/credit union into Westlaw and it came back with 85 cases, many of which have been decided within the past year.  Secondly, a rule promulgated by the CFPB banning class action arbitration charges was repealed by Congress and President Trump, albeit after a 50-50 vote in the Senate.

Equally as important, the Supreme Court has made it quite clear that state courts have very narrow grounds upon which to invalidate arbitration clauses.  “Simply put, even though contract law is governed by state law, the Federal Arbitration Act demonstrates a strong federal commitment to ensuring that individuals have the right to arbitrate disagreements.” DIRECTV, Inc. v Imburgia, 577 US 47, 136 S Ct 463, 193 L Ed 2d 365 [2015]

Those of you who decide to go forward with these clauses shouldn’t just run a Google search and cut and paste language into your agreement.  Many arbitration clauses give your members a certain number of days to opt out of the class action ban and always clearly explain precisely what these agreements do.  Otherwise, you are engaging in precisely the type of activity which the courts will find the contracts unenforceable. 

Last, but not least, arbitration agreements and account agreements are only valid to the extent that members were given adequate notice of the language.  Your attorney should review cases in which courts found that members received adequate notice.  One more thought, some credit unions are reluctant to incorporate arbitration agreements because it just doesn’t seem like a credit union-y thing to do (hey, I just invented an adjective).  But remember, suing the credit union isn’t a particularly credit union-y thing to do, either, but with potentially millions of dollars at stake, there are going to be plenty of members willing to do so on issues ranging from NSF fees to overdraft disclosures.  Why wouldn’t you take basic steps to cut them off at the pass?

March 15, 2021 at 8:57 am Leave a comment

Is Your CU Eligible For ECIP?

On Thursday the Treasury unveiled regulations and guidance implementing the Emergency Capital Investment Program (ECIP) which sets aside $9B to invest in Community Development Financial Institutions (CDFI’s) and Minority Depository Institutions (MDI’s) which can use the money to assist communities negatively impacted by the pandemic.  It has created a lot of interest in CU Land because of its extremely attractive terms.  Funds provided to CUs under the program are interest free for the first 24 months. The program however is trickier than it appears, particularly as it relates to secondary capital.

 To be eligible for funding, your credit union must be either a CDFI or a MDI.  This means that even if your credit union has become a Low Income Credit Union (LICU) it does not qualify to participate for these loans.

Congress created the program in the second round of stimulus funding in December. Under Section 104A the program was created   

“…to support the efforts of low- and moderate-income community financial institutions to, among other things, provide loans, grants, and forbearance for small businesses, minority-owned businesses, and consumers, especially in low-income and underserved communities, including persistent poverty counties, that may be disproportionately impacted by the economic effects of the COVID-19 pandemic, by providing direct and indirect capital investments in low- and moderate-income community financial institutions.”

With this charge it is still not entirely clear how the treasury will decide how much $ eligible FIs will be awarded.

Here is where I will get a little into the weeds.  If a credit union does qualify for funding under the program your credit union will still have to be eligible for and be approved by NCUA to have the funds classified as Secondary Capital.  Otherwise it will reduce your net worth ratio.  These funds are not being set aside for financially struggling institutions they are being set aside for financial institutions in financially struggling communities.  

What regulations apply in making a secondary capital classification request?  Good question.  As readers of this blog know NCUA has approved regulations basically replacing secondary capital with subordinated debt.  However, these new regulations don’t become effective until next year.  Credit unions should follow the existing secondary capital regulations, paying special attention to this detailed and, in my ever-so-humble opinion, overly burdensome guidance on secondary capital.

Vaccine Eligibility Expansion

As you may have heard, and judging by the number of emails on the subject, many of you did, the Governor announced yesterday that vaccine eligibility would be expanded to include:

  • Public-facing government and public employees
  • Not-for-profit workers who provide public-facing services to New Yorkers in need
  • Essential in-person public-facing building service workers

At this point we are just dealing with a press release.  The Association has reached out for clarification on precisely which employees are going to be included in this expansion and once we get additional information we will pass it on.   

March 10, 2021 at 9:08 am Leave a comment

Sole Proprietors Gain Meaningful Access to PPP Loans

Even as the clock keeps ticking closer to a March 31 deadline the SBA released new regulations yesterday making it easier for sole proprietors, persons convicted of nonfinancial crimes and persons with delinquent student loans to qualify for assistance.  The expanded eligibility only applies to individuals who have not previously obtained a PPP or Second Draw Loan.   Let’s hope that these well- intended but significant changes can be quickly and accurately integrated into lending platforms and that loans can get out the door without an accompanying surge of scams and waste. Better yet, let’s hope that Congress extends the deadline so that everyone can take a deep breath and administer the program properly.

IRS Form 1040 schedule C is the form used by sole proprietors. Previously, PPP rules defined payroll costs for individuals who file an IRS Form 1040, Schedule-C as payroll costs (if any employees exist) plus net profits, which is net earnings from self-employment.  The problem is that many of these entities are the smallest of small businesses with few if any employees and many are struggling to generate net income.  Furthermore many of these are minority and woman owned businesses that the Biden administration is targeting for relief. Under these new rules the term “income” as used in the definition of payroll costs for sole proprietors and independent contractors is expanded to encompass either borrower’s net income or a borrower’s gross income.

Depending on the size of the loan being requested, it may take longer for borrowers to get through the process.  A borrower applying for a typical PPP loan certifies the accuracy of his application and the SBA reserves the right to scrutinize applications in the future.  To guard against potential abuse under this expanded eligibility if a sole proprietor reports $150,000 or more on gross income when making a PPP application the SBA borrower will not automatically be deemed to have made the statutorily required certification concerning the necessity of the loan request in good faith, and the borrower may be subject to a review by SBA of its certification.

CFPB issues QM Patch Extension

 Yesterday the CFPB issued the regulations that have been anticipated for a while under which mortgages eligible for sale to Fannie Mae or Freddie Mac will continue to qualify as Qualified Mortgages under the CFPB’s TRID regulations.  This designation gives them added protection against borrowers contesting foreclosure actions.  The CFPB is also going ahead with new regulations permitting loans to qualify as QM loans provided their interest rates are comparable to similar mortgages.  For those of you who underwrite to secondary market standards, I have not seen any word from the GSE’s as to whether or not these new type of QM loans will be automatically eligible for purchase once I do, I will let you know.

March 4, 2021 at 9:44 am Leave a comment

CFPB Puts Brakes on Mortgage Reform

Late last year, the CFPB passed a series of regulations making dramatic changes to the definition of qualified mortgages (QM) under TRID. Now, to the surprise of no one, the new leadership of the CFPB is holding off on these final regulations. This can get kind of confusing, so pay attention.

The regulations to which I am referring were finalized by the CFPB on December 10th of last year. One of the regulations created a new category of qualified mortgages, under which mortgages held in a lender’s portfolio for 36 months, which also met certain other criteria, would qualify as qualified mortgages. This distinction provides lenders with increased protections in the event the legality of the loan is challenged in a foreclosure. In finalizing the regulation, the CFPB had decided that regulations would not retroactively apply for this expanded QM definition, but also decided that the regulation would take effect March 1, 2021. In a statement yesterday, the CFPB indicated that it is going to let this regulation take effect, but that it is considering a new round of rulemaking that would amend this regulation. 

A second key development involves everyone’s favorite friend, the QM patch. The patch is that “temporary” provision, under which mortgages eligible for sale to the GSEs are classified as qualified mortgages. Also on December 10th of last year, the CFPB finalized amendments to this regulation which would replace the QM patch with a new QM definition classifying mortgages as qualified provided the interest rate terms of the loan are comparable to similar mortgages.

Currently, credit unions must be in compliance with this second regulation by July 1, 2021. In its statement yesterday, the CFPB indicated that it would also be considering making amendments to this regulation and most likely delaying the mandatory compliance deadline. 

February 24, 2021 at 9:49 am Leave a comment

Key Changes Made to New York Foreclosures, SBA Loans

Yours truly is discharging his duty to faithfully provide you with the most pertinent information to start your credit union day this morning by giving you a heads up on two recent developments that may impact your operations. First, I want to provide a snapshot of a vitally important recent decision by New York’s court of appeals clarifying how to calculate the statute of limitations for residential foreclosures in New York State. Spoiler alert: this is actually good news for New York lenders. Secondly, I have a few thoughts on the Biden Administration’s announcement yesterday of sudden and dramatic changes to the Paycheck Protection Program, with the aim of increasing the number of small businesses gaining access to these loans. 

Anyone who provides mortgage loans in New York State should make sure that they receive a summary of the decision issued late last week by New York’s court of appeals in Freedom Mortgage Corp. v. Engel. New York already has one of the longest, most complicated foreclosure processes in the country. This case resolved a series of issues which had threatened to make the foreclosure process even more difficult to execute for lenders. For example, there are two basic ways for commencing a mortgage foreclosure action in New York State and triggering the six year statute of limitations. One way is to actually go to court and file a foreclosure action. A second way is to send a delinquent borrower a notice of default. One of the questions addressed by the court of appeals was how to distinguish between putting a borrower on notice that they may be subject to a foreclosure action if they don’t make payments, and a notice that actually commences a foreclosure action. This distinction is crucial because an increasingly large number of defaults in New York take more than six years to resolve, and delinquent borrowers are claiming that the lender can no longer foreclose on their property. Fortunately, the court of appeals ruled that “even in the event of a continuing default, default notices provide an opportunity for pre-acceleration negotiation—giving both parties the breathing room to discuss loan modification or otherwise devise a plan to help the borrower achieve payment currency, without diminishing the noteholder’s time to commence an action to foreclose on the real property, which should be a last resort.” 

A second issue that has been hotly debated in New York courts is what actions stop a foreclosure action. For example, can a lender who is afraid that the statute of limitations is going to run out withdraw a foreclosure action and commence a new action in the future if they are unable to come to an agreement with the delinquent homeowner? Using wonderfully unequivocal language designed to provide lenders and borrowers in New York State a bright line rule that is easily understood, a voluntary discontinuation of a foreclosure action by withdrawal of the foreclosure complaint constitutes a revocation of the foreclosure. A lender can subsequently bring a new action with an entirely new six-year statute of limitations, even if the lender withdrew the previous action specifically to avoid having the statute of limitations run out. 

Shifting Gears to the Biden Administration and PPP

The Biden Administration announced that, starting tomorrow, SBA would be imposing a two-week window during which the agency will only accept PPP applications with 20 or fewer employees. The exclusive window will also be coupled with changes expanding who is eligible to receive PPP loans by stipulating that student loan debt and certain prior criminal convictions should not be part of the underlying criteria that constitute an effective strike against an applicant’s eligibility. I will have more to say on this as the process gets underway. While I understand what the Biden Administration is trying to accomplish, I’m more concerned with the speed with which they expect these changes to take effect. At the risk of sounding like an aging elementary school teacher in a 1950s sitcom, haste makes waste. 

On that note, peace out people. Enjoy your day.

February 23, 2021 at 9:56 am Leave a comment

Four Key Issues to Know As You Start Your Credit Union Day

This morning has provided your faithful blogger with a treasure trove of important tidbits to pass on to you as you begin your credit union day. So with the caveat that many of these issues are worthy of future expansion, here goes…

Wells Fargo Folds and Settles Patent Litigation

In one of the highest-profile patent litigation cases in more than a decade, according to Law360, Wells Fargo has agreed to pay $300 million to USAA to settle claims that it violated patents related to remote deposit capture technology. The litigation was seen as a key bellwether of the extent to which financial institutions would have to enter into licensing agreements regarding this technology. Yours truly is no patent attorney, but this announcement should trigger a call to your legal counsel to discuss next steps for your credit union, particularly if it has been subject to a letter from USAA requesting that it license its RDC technology. 

Biden Administration Announces Additional Mortgage Forbearances

The Biden Administration announced yesterday that it was extending mortgage forbearance opportunities for certain government-backed mortgage loans. As a result of the announcement, the Department of Housing and Urban Development, the VA and the Department of Agriculture will extend mortgage forbearance and foreclosure relief, which were otherwise due to expire in March, until June 30th of 2021. Similar steps were recently announced by Fannie Mae and Freddie Mac. New York State has also extended forbearances for non-federally backed mortgage loans for individuals impacted by COVID-19. Let’s hope that the additional stimulus that Congress is expected to provide to consumers will allow policymakers to phase out these protections by the end of this year. Believe it or not, a properly functioning mortgage lending system is in the best interest of consumers.

New York’s Department of Financial Services Issues Cybersecurity Fraud Alert

The DFS issued a cybersecurity fraud alert informing its regulated entities that it has “recently learned of an aggressive campaign to exploit cybersecurity flaws in public facing websites to steal non-public information.” Although the guidance primarily focuses on websites designed to give consumers quick insurance quotes, the DFS is also reporting that similar attacks have been lobbed against mortgage companies. The focus of these threats is apparently to steal information such as licenses, which consumers are sometimes asked to provide when getting instant quote information. DFS is reporting that at least some of the stolen information is being used to engage in fraudulent attempts to obtain pandemic-related unemployment benefits in New York. Remember, under New York’s cybersecurity regulation (NYCRR 500.1 (g)), information that is considered “non-public” includes a name, number, personal mark or other identifier which can be used in conjunction with a social security number, drivers license, account, credit or debit card number in identifying an individual. Incidentally, you should pass this on to your vender to make sure they are aware of your New York State-based obligations. 

NCUA IG Investigates Consumer Complaint Process

As many readers of this blog know, Board Chairman Todd Harper supports increasing NCUA’s scrutiny of credit union compliance with consumer protection laws. Many individuals, including your faithful blogger, have questioned what evidence there is that compliance with consumer protection laws is lacking within the industry. An esoteric report recently issued by the inspector general investigating NCUA’s complaint review process may take on exaggerated importance in this debate. I haven’t read the entire report yet, but the inspector general is suggesting that NCUA should do a better job of making sure that examiners are aware of complaints issued against a credit union. 

On that note, enjoy your day. I would also like to extend a special thank you to the Buffalo Sabres. Two nights ago, my NY Islanders did not surrender a single shot on goal to the Sabres. This was the first time the Islanders had ever shut a team out this way since they started in the early 70s. In the immortal words of Wayne Gretzky, “you miss 100% of the shots you don’t take.”

Image result for michael scott wayne gretzky

February 17, 2021 at 10:02 am Leave a comment

HUD Prohibits Gender Identity and Sexual Orientation-based Discrimination

In one of the first examples of the dramatic impact the Biden Administration will have on housing policy, The Department of Housing and Urban Development (HUD) announced Friday that it was interpreting the Fair Housing Act as prohibiting discrimination against individuals on the basis of sexual orientation and gender identity. The announcement, which is an outgrowth of Executive Order 139.88, means that we will soon start seeing high profile enforcement actions based on alleged sexual orientation discrimination.

In one of the most important cases from its last term, the Supreme Court ruled that Title VII of the Civil Rights Act, which prohibits discrimination in employment on the basis sex, also applied to individuals discriminated against on the basis of their sexual oritentation or gender identity. In the memo released on Friday, HUD’s Office of Fair Housing and Equal Opportunity announced that the ruling extends to discrimination under the Fair Housing Act, which of course bars discrimination on the basis of race or sex. Effective immediately, HUD will “accept for filing and investigate all complaints of sex discrimination, including on the basis of gender identity or sexual oritentation.” The new announcement is intended to signal that this prohibition is going to be aggressively interpreted and enforced by HUD.

On a practical level, lenders in New York should already have policies which prohibit gender-based discrimination as a matter of state law. But now that HUD has issued this ruling, credit unions that lend in New York and in states which don’t already ban this type of discrimination should review their existing policies.

February 16, 2021 at 9:40 am Leave a comment

SBA Provides Workaround For Platform Glitches

If you are among the financial institutions that are providing PPP loans, I have some good news for you. Although the rollout of the program following its reauthorization by Congress in December has gone relatively well, it has not been without its glitches. Incidentally, I belong in the group of people who believe the SBA has done a good job administering a program doling out billions of dollars within weeks of Congressional approval. 

Under the procedural notice, lenders will be allowed to certify that a loan meets SBA requirements notwithstanding the fact that it has been flagged for rejection by the SBA platform. The updated guidance provides a list of error codes to which this flexibility will apply, such as a potential match to the OFAC sanction list, or a tax ID mismatch. The guidance explains that when a lender resolves a compliance error through this lender certification process, the lender must submit all information and documentation supporting the certification to the SBA when the lender submits a forgiveness decision or guarantee purchase request. As a result, keep in mind that the certification override is an option – not a requirement – for lenders. The guidance also points out that not all platform red flags can be resolved through this process, and provides a list of examples of the type of documentation which lenders could provide to the SBA to resolve these issues as quickly as possible. 

While we are on the subject of the PPP, today’s American Banker is reporting that more than $93 billion of the roughly $101 billion worth of loans approved by the SBA since January 12th have involved second-draw loans. I was talking to an accountant friend the other day, and as he noted, either you are comfortable relying on the government, or you simply don’t trust it enough to take it in the first place. 

Setting the Record Straight When it Comes to FOM Proposal

When I started blogging oh-so-many years ago, I quickly decided to ignore the white noise of banker attacks as much as possible. After all, there’s only so much you can say on the same topic, and when it comes to dealing with the inevitable attacks, the industry has to be able to walk and chew gum at the same time. But, I’m more than a little amused this morning by the banking industry’s reaction to a common-sense proposal by the NCUA. 

Under existing regulations, only multiple common-bond credit unions that qualify as investors in a shared branching network, such as New York’s USNet, can use the branches in that network to satisfy physical facility requirements. Mere participants in such a network cannot. This distinction is of course arbitrary, since any credit union which contracts to participate in a shared branching network is making a legal commitment to helping other participating credit unions and their members, regardless of their status as an investor in the network. In fact, the existing regulation simply makes it more difficult for smaller credit unions to fully realize the benefits of shared branching. In other words, this is the latest example of how banker opposition hurts consumers by minimizing the potential financial options that could be made available to them. I strongly suspect that the banker’s hyperbole is motivated by a desire to signal their concern to steps that NCUA may take to further expand field of membership flexibility in the aftermath of the decision by DC’s court of appeals to uphold NCUA’s field of membership improvements. 

Sounds like it’s time to get the lawyers and money ready to go. Personally, I can’t wait.

February 11, 2021 at 9:46 am Leave a comment

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Authored By:

Henry Meier, Esq., Senior Vice President, General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

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