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From the editors of CCH’s Banking and Finance publications, this
update describes significant developments covered in our products in recent
reports, as well as product enhancements.
Market Crisis Resources,
included below, provides links to vital information on the current market
crisis.
A Hot Topic is included
below to provide guidance on researching an issue of current interest.
Past issues of the Banking and Finance
Update can be viewed on the Banking and Finance Web page at: http://business.cch.com/updates/bankingFinance.
If you have questions or comments concerning
the information provided below, please contact the Banking and Finance
Update editor at Serena.Lynn@wolterskluwer.com
Federal Banking Law Reporter
Treasury Unveils Public-Private Investment
Program
The Treasury Department on March
23, 2009, outlined its plan to create a Public-Private Investment Program
to deal with the problem of "legacy assets"—also called
"toxic assets"—held on the balance sheets of financial
institutions and stymieing the flow of credit in the economy. The Public-Private
Investment Program will use $75 to $100 billion in Troubled Asset Relief
Program (TARP) funds, in addition to capital from private investors, to
buy up toxic assets in the form of real estate loans held directly on
the books of banks and securities backed by loan portfolios. This story
appears in Report
Letter No. 2311, March 26, 2009 (ip
access user)
Fed to Increase Balance Sheet to Stimulate
Recovery
With the economy continuing to contract and no room remaining
for interest rate cuts, the Federal Open Market Committee decided at its
meeting that ended on March 18, 2009, to increase the size of the Federal
Reserve Board's balance sheet in an effort to stimulate economic recovery.
As expected, the Committee also voted to maintain the federal funds rate
target at 0 to .25 percent. The Fed will purchase an additional $750 billion
of agency mortgage-backed securities, for a total of $1.25 trillion in
2009. It also will increase its purchases of agency debt by $100 billion,
for a total of up to $200 billion this year. Finally, up to $300 billion
of longer-term Treasury securities will be purchased. This story appears
in Report
Letter No. 2310, March 20, 2009 (ip
access user).
Deposit Insurance Costs to Increase
The FDIC has imposed a special assessment on insured depository
institutions and also has increased the base assessment rates in steps
toward restoring the Deposit Insurance Fund reserve ratio to the required
1.15 percent. A 20-basis point emergency special assessment will be imposed
on June 30, 2009, and collected on Sept. 30, 2009, and the interim rule
the FDIC adopted permits a second, 10-basis point assessment if it is
necessary. Related documents begin at ¶95-780
(ip
access user).
Mortgage Loan Modification Guidelines
Issued
The Treasury Department has
released the guidelines that outline which consumers will be eligible
for mortgage loan modifications under the Obama administration's "Making
Home Affordable" program. The guidelines also set out the modification
terms, the incentive payments that lenders and servicers may receive,
and transparency and accountability requirements. According to the Treasury,
the two aspects of the program—one which will offer refinancing
loans and one which will offer modification of existing loans—could
help as many as nine million homeowners, with four to five million homeowners
being able to refinance their loans and three to four million being able
to obtain loan modifications. Related documents are reported at ¶95-788
(ip
access user).
State Member Banks Warned About Funding
Sources
The Federal Deposit Insurance Corp. has told the banks it supervises
to beware of relying on funding sources such as brokered or Internet deposits,
deposits that are newly insured under the temporary FDIC programs, secured
borrowings or other wholesale funding sources. Reliance on these funding
sources could increase the institution's risk profile and also increase
the risk to the deposit insurance fund, the agency said. As a result,
affected institutions will be subject to heightened supervisory review
and enforcement and may be charged higher deposit insurance premiums.
FIL-13-2009 is reproduced at
¶47-986 (ip
access user).
Simultaneous Notification Required
for Interest Rate Increase
A credit card lender that imposed
a discretionary interest rate increase on a consumer who made a late payment
was required by the Truth in Lending Act and Reg. Z to provide a contemporaneous
notice of the increase, the U.S. Court of Appeals for the Ninth Circuit
has decided. Including the notice only in the following periodic statement,
after the increase took effect, could have been a violation of TILA and
Reg. Z, the court said. McCoy v. Chase Manhattan Bank (9thCir)
is reported at ¶101-074
(ip
access user).
OTS Guides on Documenting Use of Federal
Funds
The Office of Thrift Supervision has issued guidance on monitoring
and documenting the use of funds from federal programs. In a recent letter
to federal thrift chief executive officers, the OTS stressed that savings
associations participating in federal financial stability and guaranty
programs are expected to document how their participation supports prudent
lending and/or their efforts to work with borrowers to avoid preventable
foreclosures. To that end, each institution should implement a process
to monitor its use of the funds. CEO Letter 295 is reported at ¶95-822
(ip
access user).
Product Enhancements
Basel II Capital Rules Explanations
and Issuances Updated and Reorganized
Updated explanations and supplementary
source material on the Basel II capital rules have been added as part
of a reorganization of materials in the “Capital—Basel II”
division in the Federal Banking Law Reporter Researcher. The discussion
of the regulatory requirements is reproduced at
¶47-151—¶47-157 (ip
access user). The International Convergence of Capital Measurement
and Capital Standards: A Revised Framework Comprehensive Version is
reproduced at ¶47-161
(ip
access user). For further information on coverage of Basel II regulatory
requirements, see the Hot Topic of the Month at the end of this Update.
Market
Crisis Resources
This section provides links to vital information
on the current market crisis. We offer a compendium of product coverage,
including report letter stories, white papers, primary source documents
(for example, agency issuances and legislative developments) and other
information to help track and understand the recent market upheavals and
ensuing regulatory response.
· See the new CCH
Financial Crisis News Center for news and links to vital information
on the current financial crisis, including a repository of primary
source material and analytical content. The list below is an excerpt
of CCH Subscriber resources found at the Financial Crisis News Center,
showing items reported in the Federal Banking Law Reporter during February.
Congress
Legislative Materials
- Oversight Panel Issues "Roadmap"
for Foreclosure Mitigation, March 6, 2009, ¶95-806
(ip
access user)
- Congress Issues AIG Restructuring Report,
March 2, 2009, ¶95-797
(ip
access user)
- Report Provides Valuation Analysis of TARP
Transactions, Jan. 27, 2009, ¶95-779
(ip
access user)
- Dodd Statement on Executive Compensation
Amendment in H.R. 1—the American Recovery and Reinvestment Act
of 2009, Feb. 12, 2009, ¶75-159
(ip
access user)
- Excerpt of Conference Report to Section
7001 of H.R. 1—the American Recovery and Reinvestment Act of 2009,
Feb. 12, 2009, ¶75-158
(ip
access user)
Federal Deposit Insurance Corporation
Agency Issuances
Federal Reserve Board
Agency Issuances
- TALF Expanded to Include Additional Collateral
Types, March 19, 2009, ¶95-825
(ip
access user)
- AIG Discloses Counterparties to Lending
Transactions, March 15, 2009, ¶95-814
(ip
access user)
- Fed Updates Frequently Asked Questions Regarding
Central Bank Liquidity Swaps, March 12, 2009, ¶95-807
(ip
access user)
- Credit Default Swap Clearing Arrangement
Approved (ICE US Trust LLC), March 4, 2009, ¶101-071
(ip
access user)
- Agencies to Begin Forward-Looking Economic
Assessments, Feb. 25, 2009, ¶95-769
(ip
access user)
- Holding Companies Cautioned About Capital
Reductions, Feb. 24, 2009, ¶47-675
(ip
access user)
- New Website Section on Credit and Liquidity
Programs Launched, Feb. 23, 2009, ¶95-767
(ip
access user)
- Exemption Granted from Risk-Based Capital
Guidelines, Feb. 20, 2009, ¶80-420
(ip
access user)
- Temporary Relief Granted from Risk-Based
Capital Guidelines, Dec. 22, 2009, ¶80-419
(ip
access user)
Interagency Statements
New York Attorney General
- Cuomo Sends Letter to Congressman Frank
Regarding Bonuses Paid at AIG, March 17, 2009, ¶95-821
(ip
access user)
- Cuomo Sends Letter to Edward M. Liddy, Chairman
& CEO of AIG Regarding Compensation Arrangements, March 16, 2009,
¶95-819
(ip
access user)
Office of the Comptroller of the Currency
Agency Issuances
Office of Thrift Supervision
Agency Issuances
Securities and Exchange Commission
Releases
- Exemptions Allowing ICE US Trust LLC to
Operate as Central Counterparty for Credit Default Swaps, Release No.
34-59527 (March 6, 2009), ¶95-805
(ip
access user)
Staff Guidance and No-Action Letters
Treasury Department
Agency Issuances
- Mortgage Relief Information Website Created,
March 19, 2009, ¶95-826
(ip
access user)
- Letter from Secretary Timothy Geithner to
Congressional Leadership on American International Group, March 17,
2009, ¶95-823
(ip
access user)
- Program to Stabilize Automobile Industry
Suppliers Established, March 16, 2009, ¶95-827
(ip
access user)
- Monthly Lending Survey and Intermediation
Snapshot Released, March 16, 2009, ¶95-817
(ip
access user)
- Geithner Urges Banks to Extend Credit to
Small Businesses, March 16, 2009, ¶95-816
(ip
access user)
- Geithner Calls for International Cooperation
on Recovery, Reform, March 14, 2009, ¶95-812
(ip
access user)
- Geithner Statement at G-20 Meeting Outlines
Steps to Reform, March 11, 2009,
¶95-808 (ip
access user)
- Credit Default Swap Clearing Arrangements
Approved, March 11, 2009, ¶95-800
(ip
access user)
- Mortgage loan modification guidelines issued,
March 4, 2009, ¶95-788
(ip
access user)
- Term asset-backed securities loan facility
begins operations, March 3, 2009, ¶95-785
(ip
access user)
- AIG to Receive Up to $30 Billion in New
Government Aid, March 2, 2009, ¶95-778
(ip
access user)
- Treasury Department Releases Latest TARP
Report to Congress, Feb. 28, 2009, ¶95-799
(ip
access user)
- Treasury Department Makes TARP/CPP Contracts
Available, Feb. 20, 27, 2009,
¶95-795 (ip
access user)
- FAQs Issued on Redeeming Capital Purchase
Program Shares, Feb. 26, 2009, ¶63-778
(ip
access user)
- SIGTARP Issues Q&A on Use of Funds Letter,
Feb. 25, 2009, ¶95-789
(ip
access user)
- Terms of Capital Assistance Program, Feb.
25, 2009, ¶95-771
(ip
access user)
- Statement on Capital Assistance Program,
Feb. 23, 2009, ¶95-768
(ip
access user)
- TARP/CPP Contracts Available, Feb. 13, 2009,
¶95-772
(ip
access user)
FEDERAL BANKING NEWS SOURCES
- Advance Release Documents, provides federal
Banking highlights of significant current events and regulatory activity
(See, for example, Feb.
2, 2009 (ip
access user)).
- The Federal Banking Law Report Summary provides
the news of the week (See, for example, Federal
Banking Report No. 2307, Feb. 26, 2008 (ip
access user)).
- The Federal Banking QuickChart for Current
Developments can be used to find and track regulatory action and legislation
(See e.g., under Agency Guidance—Capital, an Oct. 14, 2008, announcement
that the Treasury Department, Fed and FDIC announced a plan to purchase
up to $250 billion of preferred shares in financial institutions).
- Bank Digest Online is a comprehensive daily
journal of current events and regulatory activity providing an abstract
and the full text of the day’s releases (See, for example, Feb.
27, 2009 (ip
access user) which includes a legislative update).
- Subprime, Mortgage and Securitization Law
Update is a monthly newsletter, with frequent Current Developments updates
on the CCH Internet Research NetWork, providing coverage of regulatory,
legal and industry developments involving subprime lending, securitization
reform and the financial crisis (See, for example. Feb.
27, 2009 (ip
access user)).
Subprime, Mortgage and Securitization
Law Update
Geithner Seeks Expanded Power Over
Non-Bank Financial Firm
Treasury Secretary Timothy Geithner
told Congress that his agency should have the legal means to manage the
orderly restructuring of a large, complex, non-bank financial institution
that poses a threat to the stability of the financial system. "The
administration proposes legislation to give the U.S. government the same
basic set of tools for addressing financial distress at non-banks as it
has in the bank context," Geithner told the House Financial Services
Committee on March 24, 2009. This story appears in the March
27, 2009 update (ip
access user).
Website Created to Help Consumers Estimate
Mortgage Payment Reductions
The Treasury Department and the Department of Housing and Urban
Development have launched a new website for consumers seeking information
about the administration's Making Home Affordable loan modification and
refinancing program. MakingHomeAffordable.gov
offers features including interactive self-assessment tools that are intended
to help borrowers determine if they are eligible to participate and calculate
the monthly mortgage payment reductions they could realize under the Making
Home Affordable program. This story appears in the March
23, 2009 update (ip
access user).
President Obama Defends Budget Policy
President Obama on March 17
made the case for his budget blueprint and said that critics of the plan
should offer "constructive alternative solutions." Obama noted
that the administration's budget does not attempt to resolve every problem
or tackle every issue. However, the president pledged that he would not
cut back on those areas that he said are key to long-term economic growth,
namely health care reform, education, energy and middle income tax relief.
This story appears in the March
19, 2009 update (ip
access user).
GAO Says Restrictions Hamper SEC's
Ability to Regulate Credit Default Swaps
A report by the Government Accountability Office (GAO) to Congress
on credit default swaps (CDS) concluded that the U.S. market for these
instruments is largely unregulated and contains a number of risks. The
report should aid in the drafting of legislation creating a systemic risk
regulator. Participants in the CDS market include banks, brokerage firms
and hedge funds. The report was presented as testimony before a House
subcommittee hearing on systemic risk regulation. This story appears in
the
March 16, 2009 update (ip
access user).
Bankruptcy Trustee Files $1 Billion
Suit Against First Magnus Executives
A bankruptcy litigation trustee has filed a $1 billion lawsuit
against former executives of failed Alt-A wholesale lender First Magnus
Financial Corp. for excessive spending. The trustee, Larry Lattig, has
accused the executives of allegedly overpaying themselves hundreds-of-millions
of dollars as the company was sinking. According to the suit, two weeks
before a bankruptcy filing by the firm, which employed more than 5,000
people, executives took the corporate jet to a Hawaiian resort. Lattig
represents creditors in the case. This story appears in the March
10, 2009 update (ip
access user).
Consumer Credit Guide
Fed Proposes to Amend Disclosure Requirements
for Private Education Loans
The Federal Reserve Board has proposed amendments to Regulation
Z (Truth in Lending) that would revise the disclosure requirements for
private education loans. Under the proposed amendments, lenders extending
private education loans would be required to: provide disclosures about
loan terms and features on or with the loan application; disclose information
about federal student loan programs that may offer less costly alternatives;
and provide additional disclosures when the loan is approved and when
the loan is consummated. The Fed has also drafted model disclosure forms
that creditors would use to comply with the new disclosure requirements.
Federal Agency Releases, ¶30,137
(ip
access user).
Collector’s Statement Hinges
on “Unsophisticated Consumer’s” Perspective
The U.S. Court of Appeals for
the Seventh Circuit issued opinions in three cases addressing the issue
of whether a debt collector’s statement in a collection letter could
be considered “false” in violation of the federal Fair Debt
Collection Practices Act (FDCPA). In each case, the Seventh Circuit rejected
the argument posed by the respective consumers that the only determination
for the court was to determine the falsity or accuracy of the statement
itself. The court emphasized that even if a collector’s statement
could be considered “false” in a technical sense, the statement
would not violate the FDCPA if it would not mislead or confuse an “unsophisticated
consumer.” The court focused on the materiality of the collector’s
statements, whether the objective “unsophisticated consumer”
would rely upon the statement, whether the consumer would be confused
by the statement, and whether the statement obscured or overshadowed other
language in the collection letter. Wahl v. Midland Credit Management,
Inc. (7thCir) ¶52,232
(ip
access user); Hahn v. Triumph Partnerships, LLC (7thCir)
¶52,235
(ip
access user); and Muha and Cajski v. Encore Receivable Management,
Inc. (7thCir) ¶52,236
(ip
access user).
State Law Update
Oregon: The Department of
Consumer and Business Services (DCBS) has revised the annual licensing
fee for consumer finance licensees. For short-term lender applicants
or licensees, the fee is $750 for an initial application for each location
to be licensed and $750 for the renewal of a license for each licensed
location. Previously, the fee for each was $1,200. Regulation at Oregon
¶8030
(ip
access user).
Smart Charts Highlights
Some of the latest changes reflected in Consumer
Credit Smart Charts include:
- Consumer Credit Topics Smart Charts.
The Interest-Usury Topics Smart Chart reflects the current monthly
and quarterly interest rate modifications for April 2009.
- The Legislative Developments Smart
Charts now are updated regularly as legislation is enacted,
allowing users to keep up to date without waiting for a scheduled
report. Links to legislative summaries and to full text of laws amended,
repealed or added are provided. Recent updates include:
- Arkansas: Identity
Theft Protection—Consumer Report Security Freeze Act.
- Colorado: Uniform
Consumer Credit Code; Debt Management Services.
- Kentucky:
Deferred Deposit Transactions.
- Mississippi: Identity
Theft—Fraudulent Use of Another's Identity.
- Oregon:
Credit Cards—Fraudulent Use—Crimes.
- Utah: Uniform Consumer
Credit Code, Mortgage Lending and Servicing; Collection Agencies,
Exemptions.
- Wyoming: Uniform
Consumer Credit Code—Mortgage Loan Originators; Rental Vehicle
Agencies.
Secured Transactions Guide
Untimely Perfection Costs Creditor
Its Lien
A debtor could avoid a finance
company's lien perfected within 90 days of the debtor's filing of a petition
for bankruptcy as a preferential transfer because the finance company
failed to timely perfect its lien. The debtor financed a vehicle on January
15. The finance company submitted an application to perfect its lien on
the vehicle title on February 29. The debtor filed a petition for bankruptcy
on April 18. The bankruptcy trustee sought to avoid the finance company's
lien on the vehicle. The Bankruptcy Code provides that a creditor's security
interest perfected within 90 days prior to the debtor's filing for bankruptcy
relief may be avoided as a preferential transfer. The finance company
argued that its lien was perfected on the date of sale, more than 90 days
prior to the filing of the petition. Alabama law provides if an application
for a certificate of title is delivered within 30 days of the sale of
the vehicle, the lien is perfected as of the date of sale. However, the
finance company's application was received more than 30 days after the
sale. The excuse that failure to timely perfect was "a standard practice
in the automotive industry" was not a recognized exception to the
law. In re Baker; Reding v. T.R. Motors, Inc. (Bankr MDAla) appears
at ¶56,179
(ip
access user).
Financing Statements Were Not Seriously
Misleading
Financing statements which incorrectly
identified collateral were not so misleading as to render them ineffective.
Because the description identified all of the debtor's assets as collateral,
it was incumbent on subsequent creditors to investigate whether the collateral
at issue was covered by the security agreement. A debtor assigned its
interest in two insurance annuity contracts as collateral. The financing
statements described the collateral as "all of Debtor's right, title,
and interest in and to, assets and rights of Debtor” but listed
the wrong issuer and policy numbers for the annuity contracts. The debtor
subsequently assigned its interest in the same two annuity contracts to
a second creditor. The second creditor argued that the financing statements
filed by the original creditor were seriously misleading. A financing
statement is not seriously misleading if "it provides notice that
a person may have a security interest in the collateral claimed."
Any errors in describing the annuity contracts were immaterial, because
the financing statements identified all of the debtor's assets as collateral.
ProGrowth Bank, Inc. v. Wells Fargo Bank, N.A. (8thCir) appears
at ¶56,180
(ip
access user).
State Law Update
Colorado: New requirements
for certificate of titles to manufactured homes have been added in Colorado.
Where an applicant for a certificate of title to a manufactured home
is unable to provide sufficient evidence of ownership, surety for the
certificate of title will no longer be required for manufactured homes
25 years old or older, if certain statutory requirements are met. Other
requirements have been added for manufactured homes affixed to the ground
prior to July 1, 2008, where no certificate of permanent location was
filed or recorded and for manufactured homes that occupy real property
subject to a long-term lease with an express term of at least ten years.
The law begins at Colorado ¶1206
(ip
access user).
Nebraska: A change in the
provision regarding the effect of errors or omissions on a filed financing
statement that was originally to take effect Sept. 2, 2009, has been
delayed until Sept. 2, 2010. The revised provision will specify that
if a search of the records of the filing office under the debtor's correct
name, using the filing office's standard search logic, would disclose
a financing statement that fails to sufficiently provide the name of
the debtor, the name provided does not make the financing statement
seriously misleading. The law appears at Nebraska ¶R816
(ip
access user).
Wyoming: The law relating
to motor vehicle certificates of title has been revised. Among other
changes, a Wyoming certificate of title must contain an appropriate
notice whenever records readily accessible to the state indicate that
the motor vehicle was previously issued a title or registration from
any jurisdiction that bore any word or symbol signifying that the vehicle
was "salvage", "unrebuildable", "parts only",
"scrap", "junk", "nonrepairable", "reconstructed",
"rebuilt" or any other symbol or word of like kind, or that
it has been damaged by flood. Additional requirements have been added
for titling rebuilt, salvage, damaged or reconstructed vehicles and
selected definitions have been revised. The law begins at Wyoming ¶1101
(ip
access user).
Smart Charts Highlights
Latest Changes Reflect Updated Filing
Fees
The Secured Transactions UCC
Filing Fees Smart Chart has been updated to reflect filing fee changes
in North Dakota that will take effect Aug. 1, 2009, and additional changes
in South Dakota that will take effect July 1, 2009.
Financial Privacy Law Guide
CRA Settles FTC Charges for Failure
to Screen
A consumer reporting agency
(CRA) that allegedly failed to properly screen prospective customers and,
as a result, sold more than 300 credit reports to identity thieves has
settled charges brought by the Federal Trade Commission that it violated
the Fair Credit Reporting Act (FCRA). According to the FTC's complaint,
the CRA used credit information, including consumers' names, Social Security
numbers, birth dates, bank and credit card account numbers and credit
histories from other consumer reporting agencies to create reports that
landlords then used to assess potential renters. However, the company
failed to properly screen new customers. It did not require an applicant
to submit any supporting documentation that it was a landlord. As a result,
identity thieves posing as property owners were given an account with
unlimited access to credit reports, and the account was used to access
at least 318 reports containing sensitive personal information. United
States v. Rental Research Services, Inc. (DMinn) appears at ¶100-425
(ip
access user).
FACT Act Does Not Violate Fifth, Fourteenth
Amendments
A federal district court in
Illinois held that the Fair and Accurate Credit Transactions Act (FACT
Act) does not violate the U.S. Constitution, thus allowing a class action
suit to proceed. A consumer had visited the Skydeck at the Sears Tower,
a popular tourist attraction in Chicago, paid for admission with a credit
card, and received a computer-generated receipt that contained the expiration
date of his card in violation of the FACT Act. The court rejected the
Skydeck operator’s argument that the FACT Act violates the due process
clause because the range of statutory damages combined with punitive damages
is impermissibly vague and excessive and constitutes impermissible “double
punishment.” The court also rejected the argument that the FACT
Act violates the Equal Protection clause because it exempts handwritten
and imprinted credit card receipts. A story on Irvine v. 233 Skydeck,
LLC (NDIll) appears in Privacy
Extra, March 31, 2009 (ip
access user).
Credit Monitoring Costs Are Not Actual
Damages Under FACT Act
A consumer who failed to allege any injury to his credit or identity
could not maintain an action against a utility company for its negligent
noncompliance with the credit card truncation requirements of the Fair
and Accurate Credit Transaction Act (FACT Act). According to a federal
district court, credit monitoring costs do not constitute actual harm
under the Act. A story on Aliano v. Armiegas Partners, L.P. (NDIll)
appears in Privacy
Extra, March 31, 2009 (ip
access user).
GLBA Does Not Completely Preempt State
Law Claims
A federal district court has
ruled that the Gramm-Leach-Bliley Act (GLBA) does not completely preempt
state consumer protection laws. As a result, a consumer class action brought
against a bank for violations of state consumer protection laws for the
bank's alleged failure to protect the consumers' nonpublic information
could not be removed to federal court. The Act provides that a state law
is preempted only to the extent that it is inconsistent with the provisions
of the GLBA. Congress did not intend the GLBA to provide the exclusive
cause of action when a financial institution fails to protect the privacy
of its customers and the security of those customers’ nonpublic
information. A story on C.S. v. United Bank, Inc. (SDWV) appears
in Privacy
Extra, March 31, 2009 (ip
access user).
Bankruptcy Law Reporter
Failure to File Financial Disclosures
Does Not Warrant Automatic Dismissal
In an issue of first impression,
the U.S. Court of Appeals for the First Circuit has determined that a
bankruptcy court may enter an order excusing nondisclosure of the items
required under Bankruptcy Code Sec. 521(a)(1)(B)(iv) after the time for
filing the required information has expired. Chapter 7 debtors were not
permitted to “game the system” and obtain “automatic
dismissal” of their case by citing their own failure to file payment
advices or other financial disclosure information in an effort to avoid
losing an asset to the Chapter 7 trustee. Acosta-Rivera and Balseiro-Chacon
(1stCir) ¶81,430
(ip
access user)
Trustee Has Standing to Oppose Motion
to Reclassify
A Chapter 13 trustee, who is charged with assuring that claims
are properly disbursed, has standing to object to a motion to reclassify
a claim. Because a trustee must be able to verify that secured claims
are, in fact secured, it necessarily follows that a trustee has standing
to object when a debtor attempts to reclassify a secured claim as an unsecured
claim. Overbaugh (2ndCir) ¶81,438
(ip
access user)
Limited Stay Relief Order Could Not
Be Expanded to Bar Discharge
A creditor’s state court
judgment lacked preclusive effect to establish the elements of a Sec.
523(a)(2)(A) nondischargeability claim. The fraudulent misrepresentation
claim pursued by the creditor in state court was outside the scope of
a bankruptcy court order that granted limited relief from the automatic
stay to allow the creditor to proceed against bonding companies, not the
debtor. The judgment in the pending state court action was effective only
as to those claims actually pending in the state court at the time the
order modifying the stay issued or that were expressly brought to the
attention of the bankruptcy court during the relief from stay proceedings.
Wardrobe (9thCir) ¶81,446
(ip
access user)
Bankruptcy Legislation
The House of Representatives
has passed H.R. 1106, the Helping Families Save Their Homes Act of 2009,
also known as the “cramdown” bill, would allow bankruptcy
judges to modify the loan terms for families with existing mortgages on
their primary residence when they have exhausted other options. Under
H.R. 1106, the court can reduce the mortgage only to the current fair
market value of the house. Judges may also reduce the interest rate, reduce
the principal or extend the life of an existing loan. The bill seeks to
ensure that bankruptcy is avoided whenever possible, with families having
to demonstrate that they have made good faith efforts to get a loan modification
outside of bankruptcy. Homeowners would also have to share the increase
in property value with the lender for five years. The bill has been referred
to the Senate Committee on Banking, Housing and Urban Affairs
Individual Retirement Plans
Guide
Lump-Sum Distribution from Plan to
Roth IRA Allowed
The IRS has ruled that mandatory retirement deductions, discretionary
contributions and voluntary contributions to certain qualified plans,
if distributed in a lump-sum distribution from a plan, could be rolled
over into a Roth IRA. The related interest was subject to taxation with
respect to the tax year of the distributee or recipient in which the amount
was distributed. IRS Letter Ruling 200909074 is reported at ¶6125
(ip
access user).
Hot
Topic of the Month
This month’s Hot Topic of the Month is
the Basel II capital rules for banks. Extensive coverage
of the federal banking agencies’ Basel II regulatory requirements
is found in the Federal Banking Law Reporter and Bank Digest.
The Basel Committee on Banking Regulations
and Supervisory Practices comprises representatives of the central banks
and supervisory authorities of the Group of Ten countries. The Group of
Ten countries include Belgium, Canada, France, Germany, Italy, Luxembourg,
Japan, the Netherlands, Sweden, Switzerland, the United Kingdom, and the
United States. The Basel Committee meets at the Bank for International
Settlements in Basel, Switzerland and is an organization in which these
major banking regulators have coordinated an internationally recognized
risk-based capital framework.
The regulatory provisions require some banking
organizations, referred to as "core banks," to use an internal
ratings-based approach to calculate regulatory capital requirements for
credit risk and an advanced measurement approach to calculate regulatory
capital requirements for operational risk. Core banks are generally a
group of large and internationally active U.S. banking organizations.
Other banking organizations may opt-in to use their own internal ratings-based
and advanced measurement approaches provided they meet certain qualification
requirements.
The Federal Banking Law Reporter Researcher
“Capital—Basel II” division provides a compilation of
CCH explanations and official source material. An editorially authored
discussion of regulatory requirements is found at ¶47-151—¶47-157
(ip
access user).
The International Convergence of Capital
Measurement and Capital Standards: A Revised Framework Comprehensive Version
is reproduced in its entirety at ¶47-161
(ip
access user). This document is a compilation of the June 2004 Basel
II Framework, the elements of the 1988 Accord that were not revised during
the Basel II process, the 1996 Amendment to the Capital Accord to Incorporate
Market Risks, and the 2005 paper on the Application of Basel II to Trading
Activities and the Treatment of Double Default Effects.
The bank regulatory agencies—Office of
the Comptroller of the Currency, Federal Reserve Board, Federal Deposit
Insurance Corp. and Office of Thrift of Supervision—have implemented
the Basel II Internal Ratings Based Approach for Credit Risk and the Advanced
Measurement Approaches for Operational Risk. The Advanced Capital Adequacy
Framework Regulations are codified and reproduced in Federal Banking Law
Reporter Regulations as follows:
The agencies have also issued interagency statements
on the application of Basel II:
- Qualification Process for Advanced Approaches
Risk-Based Capital Framework Implementation, July 8, 2008, ¶47-130
(ip
access user)
- Interagency Guidance on Supervisory Review
of Capital Adequacy (Pillar 2), July 15, 2008, ¶47-131
(ip
access user)
Comprehensive coverage of any announcements
or statements by banking regulators relating to the Basel Committee can
be found in Bank Digest. For example:
- The FDIC has issued support for the work
of the Basel Committee on Banking and Supervision and the International
Association of Deposit Insurers (IADI) on issuing the Core Principles
for Effective Deposit Insurance Systems for public consultation. The
core principles address a range of issues including deposit insurance
coverage, funding and prompt reimbursement. They also address issues
related to public awareness, resolution of failed institutions and cooperation
with other safety net participants including central banks and supervisors.
Bank
Digest, March 18, 2009 (ip
access user).
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