Posts tagged ‘PPP’

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

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

What’s Old is New Again – BSA Takes Center Stage

Let’s face it – these are heady days for cyber criminals. Crypto currencies provide an ideal means to facilitate illicit payments, an unprecedented number of people are working from home, the worldwide economic slowdown ensures a steady supply of potential fraudsters, particularly in countries that look the other way at this type of crime, and you have the US government throwing unprecedented amounts of money to consumers in as quick a way as possible. Put this all together and, in my ever so humble opinion, (at least in the short term) your credit union has to dedicate more of its compliance resources to ensure it is taking the steps necessary to detect and react to nefarious cyber activities, i.e. the “red flags” of criminal activity. 

Recently, there has been a sharp increase in the number of advisories of which your credit unions should be aware. With regard to PPP loans, FinCEN recently sent updated guidance reiterating your due diligence requirements and confirming what procedures can be used when assisting individuals applying for “second draw” PPP loans. This guidance is particularly useful for navigating your beneficial owner obligations. Remember that the PPP loan application requires you to identify any owner with a 20 percent stake in an applicant’s business, whereas FinCEN’s beneficial owner requirements kick in for individuals with a 25 percent stake. 

Just yesterday, FinCEN issued this guidance providing examples of how fraudsters are gaming the system to facilitate healthcare fraud. One of the examples it provided involved an individual who set up several shell pharmaceutical companies to get reimbursement for transactions that never took place. It looks like somebody better call Saul (for the uninformed, that is a Breaking Bad reference). 

The Anti-Money Laundering Act of 2020 contained in the National Defense Authorization Act ordered FinCEN to provide guidance to financial institutions that are asked by law enforcement to keep an account open, even though they suspect or know that it is being used to facilitate criminal activities. The statute provides that financial institutions honoring such “keep open requests” shall not be liable for maintaining the account. This guidance, which was issued jointly by all the federal financial regulators, including the NCUA, implements this language. Finally, I want to remind you all of the guidance issued in October related to financial institutions that facilitate ransomware payments. Statistically speaking, there is a very good chance that many of your credit unions will either facilitate a ransomware payment, or be victimized by a ransomware attack. As I explained in this blog from the fall, OFAC is reminding third parties like insurance companies, banks and credit unions that they could find themselves subject to strict liability penalties for facilitating these payments if they are going to individuals on the OFAC list. While yours truly continues to believe that this is a woefully misguided warning, you should all have contingency plans for dealing with a ransomware scenario, and be cognizant of its potential OFAC implications.

February 3, 2021 at 9:26 am Leave a comment

Why Your Credit Union Should Be Looking at a CDFI Designation

If I have one request of my faithful blog readers today, it is that you schedule time in the near future to consider whether or not your credit union should seek certification as a community development financial institution (CDFI). Here’s why.

First, NCUA announced that it would be opening a streamlined CDFI application round starting on January 24th. Don’t assume that your credit union is too big to qualify for the certification.

Secondly, yours truly has found no downside to getting your CDFI certification. Not only are you eligible for grants, but as we have seen with the rollout of the newest round of the PPP, CDFIs are increasingly getting regulatory and legislative priority over more traditional lenders.

Third, let’s look at the big picture. NCUA has also recently issued a letter urging multiple SEG credit unions to more aggressively pursue expanding into underserved communities. On the state level, the Legislature passed historic legislation allowing credit unions to receive public deposits from the Comptroller’s office in return for opening a branch in an underserved area. I know last year was a lousy year, and let’s be honest, 2021 isn’t exactly getting off to a better start – but what all these initiatives have in common is a desire on the part of regulators and lawmakers to see financial institutions in general, and credit unions in particular, take more aggressive steps to integrate underserved persons into the financial mainstream.

Which brings me to the last reason I want you all to at least examine whether or not you qualify for CDFI designation. In the coming years, the industry is going to be under a microscope like never before. Every credit union that makes legitimate efforts to participate in these programs is not only helping itself and its members, but the industry and our mission as a whole.

January 14, 2021 at 9:30 am Leave a comment

PPP Open For Business – For Some

You may have seen this press release from the Small Business Administration, announcing that the Paycheck Protection Program was once again open for business, but there’s a good chance that your credit union was unable to process loans. 

The SBA announced that it was providing an exclusive window to community financial institutions. This means that unless your credit union is a CDFI or MDI, an NCUA designation which includes this list of credit unions, it is not eligible to begin processing these loans (for those of you scrolling, you can find the SBAs definition at 15 U.S.C. 636 (a)). The steps taken by the SBA are in part an understandable response to the first PPP rollout. Remember all of those articles about how the big banks and their favorite clients dominated the process? The hope is that smaller institutions, which tend to give more loans to small businesses, will be more willing and able to participate if they’re guaranteed access. Still, it does mean that many credit unions are largely excluded from this first stage of the rollout.

Credit unions with less than $10 billion in assets will have exclusive rights to lending out from a pot of no less than $15 billion that’s been set aside. However, community banks with the same asset size limits are also included in this pot, as well as institutions chartered under the Farm Credit System. The good news to take away from this is that your credit union will not have to wait in line behind big banks with infrastructure set up specifically for this type of process. (Section 1102(b) of the CARES Act (Public Law 116–136)). 

First Virtual State of the State

The Governor gave the first part of – hopefully – his only virtual State of the State address yesterday. We will be looking through his proposals, but right now, it seems like the issue that could have the greatest impact on credit unions is his plan to legalize the sale and distribution of marijuana on the state level.

January 12, 2021 at 9:58 am Leave a comment

SBA sets the stage for credit unions to take lead on PPP

The SBA has issued guidance and regulations in the last three days laying the groundwork for a continuation and expansion of the Paycheck Protection Program. What’s most striking to yours truly is just how much the SBA is establishing a regulatory framework to encourage community-based lenders to take the lead in making these loans, particularly when it comes to minority and women-owned businesses. 

Most importantly, the SBA issued this guidance which describes specific set-asides for “new and smaller borrowers, for borrowers in low- and moderate-income communities, and for community and smaller lenders.” These include:

  •  $15 billion across first and second draw PPP loans for lending by community financial institutions; 
  •  $15 billion across first and second draw PPP loans for lending by Insured Depository Institutions, Credit Unions, and Farm Credit System Institutions with consolidated assets of less than $10 billion; 
  • $35 billion for new first draw PPP borrowers; and 
  • $15 billion and $25 billion for first draw and second draw PPP loans, respectively, for borrowers with a maximum of 10 employees or for loans less than $250,000 to borrowers in low-or moderate-income neighborhoods. SBA has determined that at least 25 percent of each of those set-asides will go to each one of the groups: loans to borrowers with a maximum of 10 employees and loans less than $250,000 to borrowers in low-or moderate-income neighborhoods.

In addition to this guidance, there were two important interim regulations issued. By being designated “interim,” these regulations take effect immediately upon being published in the Federal Register. One of these regulations consolidates the existing PPP regulations, and makes amendments mandated by the recently-passed federal legislation. Keep in mind that the legislation expanded the uses that PPP loans could be put to while still qualifying for loan forgiveness. 

Some large credit unions and banks have faced litigation related to the payment of agent fees. Specifically, several unsuccessful class-action lawsuits have been brought against financial institutions for refusing to pay fees to agents who assisted borrowers in submitting PPP loan applications. The updated regulations make it crystal clear that financial institutions are not on the hook to agents unless they entered into a contract with them to cover their fees. 

A third new regulation issued by the SBA deals with the eligibility of businesses to take out a second round of loans. Consistent with the legislation, institutions seeking to take a second draw will have to meet several criteria, including demonstrating a 25% reduction in gross income over the last year. 

Tier I Super Bowl Prediction

It’s that time of year again when yours truly tells you who will win the Super Bowl – a prediction so accurate that it is certified for use as Tier I capital by all the federal financial regulators and New York’s Department of Financial Services. The Baltimore Ravens will win the Super Bowl, defeating none other than the Ageless Wonder, Thomas Edward Patrick Brady, Jr., who asked Bill Belichick during a pre-game interview if he was enjoying his time off.

On that note, enjoy your weekend.

January 8, 2021 at 9:31 am Leave a comment

It’s Back! The Paycheck Protection Program, That Is

The government program everyone loves to hate, and then love again – is back in a third iteration. If everything goes according to plan and the President signs the $900 billion stimulus plan (does it concern anyone that no one seems to know what the exact number is? Then again, when you’re dealing with $900 billion, does a $100 billion here or there matter all that much?) Within 10 days of its enactment, we will be seeing regulations for new, improved, simpler and ultimately much needed rejuvenation of the Paycheck Protection Program. I’ve taken a look at the program, the guts of which you can review in Subtitle B – Community Development Investment on page 358 of this act. Suffice it to say this is not your mother’s PPP – whereas the initial legislative thrust was concerned with keeping people employed at a moment in time when we thought things would be back to normal by next June, the new program greatly expands the expenses for which loans are eligible. For example, eligible businesses can use the money for, among other things, cloud computing services. In addition, a new provision of the law makes businesses eligible for a second loan. Finally, the maximum loan size has been reduced from $10 million to $2 million, and only businesses with 300 or fewer employees are eligible for the loans. 

Now for my soapbox moment. When looking at the value of providing PPP loans, please keep in mind not only the impact on your credit union’s bottom line, but the value to the industry of the prominent participants in this program. In addition, for those of you who can go forward with these loans, please share your stories with your trades. Congress and the public are heavily invested in this program. How they perceive financial institutions engaging consumers will, in my ever so humble opinion, shape the regulations and legislation to come. One other quick note about the legislation – although some of the money is allocated towards education, it falls far short of the funds that states like New York were looking for to help offset pandemic-related costs. Brace yourselves for another unique year as the Legislature continues to operate remotely and budgetary concerns dominate even more than usual. 

On that note, yours truly is signing off until next year. Thanks for reading, with a special shoutout to those of you who took the time to comment on my musings along the way. 

December 22, 2020 at 9:26 am 1 comment

Election Post-Mortem, Continued Gridlock Means Tough Times Ahead

One thing that Barack Obama and Mitch McConnell agree on is that elections have consequences. Although the final results won’t be known for weeks, what appears to be clear from this election is that it did little more than confirm a deeply divided status quo with all sides able to point to evidence that they were the actual victors. For credit unions, this has important consequences which will shape the industry in both the near and medium term. Here is a list of some of those consequences:

  • PPP Relief Delayed – Yesterday, the Federal Reserve once again tinkered with its regulations for the Main Street Lending Program, which was designed to encourage banks and credit unions to make loans to medium-sized businesses not eligible for PPP loans. At the same time, Federal Reserve Chairman Powell issued this extremely thoughtful release in which he once again stressed that without fiscal intervention, the Fed is at the outer limits of what it can do to support a slowing economy. Although Mitch McConnell is committed to getting a stimulus bill through Congress, I really don’t see this happening with a disgruntled, lame duck President Trump in charge and two Senate elections outstanding. This delay has real consequences. The market as a whole is welcoming the apparent gridlock, but investors in regional banks are now recognizing that business activity and consumer spending will almost certainly decrease in the months ahead. 
  • The pandemic continues to spread – In case you missed it because you were glued to John King’s magic wall of vote counts, America experienced its worst single-day count of COVID-19 cases. As Federal Reserve Chairman Powell pointed out, the economy can’t get back to full strength as long as people have to worry about contracting the virus. The good news is that in the coming months, perhaps we will move away from this false dichotomy between economic growth and the need to contain the virus. The bad news is that this means one of the top priorities for your credit union, or any business for that matter, has to be discussing, maintaining and monitoring the criteria you will use in determining how to run your operations during the Second Wave. 
  • Tough times ahead in New York – Let’s be honest. The more democrats have control of the US Senate, the more aid that will come to New York State. Anyone who pays property taxes knows how badly we need it. But with hopes for a big Senate victory fading, New Yorkers are facing an unappetizing choice between budget cuts and tax increases at a time when we need more, not less, stimulus. On the bright side, the economic vice the state may well find itself in underscores the value of giving localities mandate relief in the form of credit unions being allowed to accept municipal deposits. 
  • Let’s Go Get Stoned – Five additional states legalized marijuana in some form or another on election night. Not only did New Jersey legalize cannabis, but even red states have now decided it’s time to take a puff, with Montana, Mississippi and South Dakota joining the ranks. I don’t know what it says about America that pot legalization is one of the few issues we can all agree on, but I will now bet that by the end of the next legislative cycle, banks and credit unions will have clear legal authority to provide banking services to these businesses. If you haven’t already discussed how actively your credit union wishes to engage this business or taken a deep dive into the compliance implications, now is the time. Full disclosure: I made the same prediction two years ago. 
  • Credit Union Tax Exemption is in Play – I’m always hesitant to put too much emphasis on the threat posed to credit unions and their tax exempt status. Too often, I think it distracts us from other more pressing issues. But there are four dynamics which make the coming years particularly treacherous for the industry. Even without subsequent stimulus packages, the country has gone on an unprecedented spending spree which will have to be repaid; democrats are going to be pushing hard for tax reform, especially as the pandemic exacerbates economic inequality, three – banks have already been laying the groundwork for a targeted attack against so-called “larger” credit unions and lastly – they may find common ground with the younger, more progressive AOC wing of the democratic party, which is increasingly looking to other entities – such as the Post Office and CDFIs – to provide financing for the underserved. The action points for credit unions are obvious, but if I could make myself king for a day, I would mandate that every credit union draw up a concrete list of the products, services and activities it undertakes as a result of its tax exemption. As an industry, we like to say that we don’t pay corporate taxes because we are not-for-profit institutions. In fact, we don’t pay taxes because of a policy judgment by Congress that the financial value of having not-for-profit financial institutions available to the American public outweighs the fiscal benefit of taxing credit unions. Each and every institution benefitting from that tax exemption can, should and ultimately will have to demonstrate this fact in concrete terms to elected officials anxious for cash. 

Believe it or not, there are many other points to raise, but it’s a beautiful day and I’ve depressed my readers enough. Besides, I still have to brace myself to watch the Giants play the Washington Football Team. Perhaps Ron Rivera will hand us another victory. Have a good weekend. 

November 6, 2020 at 10:25 am Leave a comment

Another Court Rules Lenders are not on the Hook for PPP Agent Fees

Good morning folks. Could this year get any stranger? Originally, I wasn’t going to do a blog today following the news that the President had contracted the COVID-19 virus, but then I realized that regardless of what happens, there are still credit unions to run, even as we wish him a speedy recovery.

I have some good news for those of you who provided PPP loans. A Manhattan federal court has now ruled that, absent a contract, lenders are not obligated to pay the fees of agents who helped businesses apply for PPP loans. The decision is in response to six separate lawsuits alleging that, under the CARES Act and its accompanying legislation, lenders were obligated to pay agent fees so that the businesses receiving the loan proceeds wouldn’t have to. 

In his decision, Judge Rakoff concluded that the purpose of the CARES Act and its regulations was to cap the amount of money agents could receive as compensation, as well as ensure proper documentation of claims to the Small Business Administration (SBA). As a result, “because plaintiffs do not allege that they entered into any agreement with defendants regarding agent fees, the Court holds that they are not entitled to any such fees. Their claims for declaratory relief must therefore be dismissed.” 

This is at least the second case in which a court has held that lenders are not obligated to compensate PPP agents. 

Unemployment Numbers Released

The Bureau of Labor Statistics just released their September unemployment report. The bad news is that while the unemployment rate is continuing to drop, there are growing signs that the economy is slowing down, including an increase in the number of “permanent job losers.” 

October 2, 2020 at 9:21 am Leave a comment

What Would Bill Withers Say?

Updated 04/07/2020 2:30pm

It’s time for everyone to take a deep breath, remember the situation we’re all in, and look at the facts when it comes to the increasingly controversial Payroll Protection Program (PPP) that was signed into law on March 27 and for which initial guidance was just released this past Thursday.

  1. Can the SBA make lenders responsible for these loans?

Concern over participation centers, in part, on well-deserved criticism of the traditional administration of the regular 7(a) SBA loan program combined with some bad memories about how Fannie and Freddie scoured loan documents to force lenders to repurchase mortgage loans for technical violations of lending procedures. A lot of lenders out there are concerned that the 100% guarantee is too good to be true, and that when the dust settles the SBA will look for reasons to deny repayment. But keep in mind when reviewing whether or not to participate in the PPP program that 1) you are not becoming a 7(a) lender for any other purpose but the PPP; and 2) so long as you collect the proper documentation coupled with the appropriate borrower certifications, the scope of your potential liability is limited. You are not engaging in traditional underwriting. You are collecting forms.

2. Should the credit union become certified to make these loans before it decides whether to participate in the program?

My answer is no, and here’s why. The CARES Act Lender Agreement stipulates as follows: “(“Lender”) hereby agrees as a condition and in consideration of authorization by the United States Small Business Administration (“SBA”) and the Department of Treasury for Lender to make Paycheck Protection Program SBA-guaranteed financing available as part of the Coronavirus Aid, Relief, and Economic Securities Act (“CARES Act”) (P.L. 116-136) to eligible recipients, as follows (the “Agreement”). . .”

3. Are the terms of the loan too restrictive for borrowers?

This is an argument being advanced by the Wall Street Journal this morning. Under the loan terms, the SBA decided to keep non-payroll costs including mortgage interest, rent and utilities to 25% of the total authorized expenditure to focus on payroll. The problem is that for many businesses, these non-payroll expenses are the bulk of their costs.

4. How will this impact my capital ratios?

This will, of course, vary by credit union. But the program does give you the option of selling these loans to the SBA as soon as seven weeks after the loan closes. If you still don’t trust the SBA, then you will be happy to know that the Federal Reserve announced that it would be purchasing PPP loans. This is huge news. There will be a secondary market and there is going to be demand for the product.  Finally, under the CARES Act, if you are one of the handful of credit unions that is already utilizing a risk based capital model, these loans have a risk weighting of zero.

5. Can I limit my participation to my members with existing accounts?

Yes, you can. This is a great compromise for those of you who want to be there for your existing members but are a bit gun shy about taking a big plunge into the program.

6. Are there compliance risks?

Absolutely. As long time readers of this blog know, my wife justifiably accuses me of being a beater of dead horses. I want to stress yet again that you have the same obligations to know your customers when making these loans as you would with any other business accounts. That means that you should identify the beneficial owners of the organization and monitor the account for unusual activity.  That being said, however, the SBA has issued this guidance providing some relief, specifically, the Q & A provides that:

If the PPP loan is being made to an existing customer and the necessary information was previously verified, you do not need to re-verify the information. Furthermore, if federally insured depository institutions and federally insured credit unions eligible to participate in the PPP program have not yet collected beneficial ownership information on existing customers, such institutions do not need to collect and verify beneficial ownership information for those customers applying for new PPP loans, unless otherwise indicated by the lender’s risk-based approach to BSA compliance.

7. What would Bill Withers do?

 Listen, I understand all the cynicism when it comes to participating in the government program, but this is a classic Bill Withers moment.  We are not for-profit cooperatives and we should be there for our members to lean on and to help them carry on.  If not now, when?  If not us, then who?



April 7, 2020 at 9:25 am Leave a comment

Older Posts

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.

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

Join 785 other followers