Pub 8 2020 Issue 2

Credit Practices Rule. Q: Regulation AA was rescinded some time ago, but is a Notice to Cosigner still required when we are doing a loan that has a cosigner?
A: Since the repeal of FRB Regulation AA (and similar rules by the Office of Thrift Supervision and National Credit Union Administration), there has not been an explicit requirement for banks, thrifts, and credit unions to give cosigners the Notice to Cosigner. Lenders under the enforcement authority of the Federal Trade Commission are subject to the FTC’s Credit Practices Rule, which requires such a notice (among other provisions).

I am honored to be a featured associate member of the Montana Independent Bankers Association. As I have interacted with my clients in the Montana banking community, I was able to glean some insight into what might be of interest to you in an article. Health benefits are one of the most expensive line items for our Montana Community Banks. The industry changes rapidly and is affected by many factors, including the healthcare system, carrier decisions, new marketplace programs, legislation and many others. In this article, I will discuss national benchmarks, address how COVID-19 could affect health benefits in the future, and review several cost management strategies available to employers.

Phew — what a year these last few months have been.
Just three months ago, many of us were on flights returning from the ICBA convention held in Orlando, Florida.

The last time I wrote the Montana bankers, I was feeling optimistic about the work being done and hopeful we’d seen the worst of the COVID-19 pandemic. While I am still optimistic, I am also realistic. We are far from through this crisis. We still haven’t been given instructions from the SBA on how to