Wednesday, January 31, 2018

Senator Hatch Writes NCUA over CUs Operating Beyond Tax-Exempt Purpose

Senate Finance Chairman Orrin Hatch (R-Utah) wrote the National Credit Union Administration (NCUA) expressing concerns that credit unions may be operating beyond their tax-exempt purpose.

"I am concerned that the credit union industry is evolving in ways that take many credit unions further from their original tax-exempt purpose," Hatch wrote in a letter to NCUA Chairman Mark McWatters.

Senator Hatch noted that the agency has watered down field of membership requirements, opened the door to secondary capital, and lifted limits on activities that are not traditionally aligned with the credit union's tax-exempt purpose.

Senator Hatch wrote that many larger "credit unions appear to operate in the same manner as taxable banks."

He also expressed reservations about tax-exempt credit unions acquiring for-profit banks.

The letter further pointed out that NCUA has not implemented 2006 recommendations by the Government Accountability Office to require federal credit unions to publicly disclose executive compensation information.

Senator Hatch requested the agency to reply by April 6 to seven questions. Topics to be addressed include field of membership, executive compensation, corporate sponsorships, and services outside of the credit union tax-exempt purpose.

Read the three-page letter below (click on images to enlarge).

A Merger Between a Bank and Credit Union Called Off

A planned merger between Honor Credit Union (Berrien Springs, MI) and the Citizens State Bank of Ontonagon has been terminated.

Read the story.

228 CUs Borrowed from Federal Reserve in Q4 2015

The Federal Reserve reported that 228 credit unions borrowed from the Discount Window 286 times during the 4th quarter of 2015.

In the third quarter of 2015, 180 credit unions borrowed from the Federal Reserve's Discount Window.

The aggregate amount borrowed during the fourth quarter of 2015 was $134,265,001.

The average amount borrowed was $469,458. However, the median amount borrowed was $10,000.

There were 35 Discount Window loans of at least $1 million from the Federal Reserve during the 4th quarter of 2017.

The largest amount borrowed from the Discount Window was $10 million by 3 credit unions -- Blackhawk Community Credit Union (Janesville, WI), Great Lakes Credit Union (Bannockburn, IL), and Premier American Credit Union (Chatsworth, CA).

Aurora Credit Union (Milwaukee, WI) visited the Federal Reserve's Discount Window 14 times during the fourth quarter of 2015.

All credit unions, except for two, borrowed under the Federal Reserve's primary credit program, which is reserved for only well run credit unions. The seasonal credit program was tapped 7 times by two credit unions.

The Federal Reserve is required by law to disclose with a two year delay information on borrowings from the Discount Window.

Tuesday, January 30, 2018

Tiny St. Elizabeth's CU Closed

The Illinois Department of Financial and Professional Regulation issued an order of liquidation to St. Elizabeth’s Credit Union of Chicago and subsequently appointed the National Credit Union Administration as liquidating agent.

Northstar Credit Union, of Warrenville, Illinois, immediately assumed most of St. Elizabeth’s Credit Union’s members, assets and loans.

Following a 60-day suspension period, the Illinois Department of Financial and Professional Regulation determined that St. Elizabeth’s Credit Union should be liquidated.

At the end of 2017, St. Elizabeth’s Credit Union had $116,449 in assets.

St. Elizabeth’s is the first federally insured credit union liquidation in 2018.

Read the order for liquidation.

Read NCUA's press release.

Bad Taxi Medallion Loans Contribute to Announced Merger of Altier CU

Financially troubled Altier Credit Union (Tempe, AZ) is being merged into America First Credit Union (Riverdale, UT) -- the 11th largest credit union in the country.

As I previously reported, Altier Credit Union had participated in taxi medallion loans, which adversely affected the credit union's operation. Due to large losses through the first 3 quarters of 2017, the credit union was significantly undercapitalized at the end of the third quarter of 2017.

Both the Arizona Department of Financial Institutions and the National Credit Union Administration have approved the merger.

The merger becomes effective on March 1, 2018.

After the merger is completed, America First CU will expand its footprint to Maricopa County, Arizona.

Here is the Altier merger FAQ.

Read the press release.

Monday, January 29, 2018

Caribbean Junket for CU Volunteers and Board Members

The Credit Union National Association is holding its volunteer conference in Punta Cuna, Dominican Republic.

The conference started on January 28, 2018 and will be held at Hotel Melia Caribe Tropical.

Hotel room rate for a single occupancy is $200 per night or $360 per person per night for a double occupancy room.

The hotel advertises pristine beaches, a championship golf course, and casino.

The opening day of the conference has a half day snorkeling cruise for attendees and their guests.

[Update, an earlier version of this post had the room rates reversed for single versus double occupancy.]

Sunday, January 28, 2018

Navy FCU Reports Net Income of Almost $1.347 Billion for 2017

For the second consecutive year, Navy Federal Credit Union (Vienna, VA) reported net income in excess of $1 billion.

Navy FCU's 2017 net income was almost $1.347 billion. This is up 12.4 percent from a year earlier.

Navy reported total income of $6.018 billion, of which $4.63 billion was interest income and $1.39 billion was non-interest income.

The top three sources of interest income were credit cards ($1.59 billion), consumer loans ($1.29 billion), and mortgages ($1.19 billion).

The top two sources of non-interest income were fee income ($470 million) and interchange revenue ($401 million).

Total operating expenses for 2017 was $2.57 billion. Provision for loan and lease losses was $1.24 billion. Interest expense was $299 million and dividends were $498 million. Other non-operating expenses were $61 million.

View 2017 income statement.

Friday, January 26, 2018

NCUA Proposed Changes to Its Call Report

The National Credit Union Administration (NCUA) is proposing to modernize its Call Report, so as to reduce reporting burdens.

The current Call Report has 1,523 account codes.

According to the new prototype Call Report, NCUA is proposing to eliminate 1,017 account codes, as most of the account codes are no longer needed.

NCUA will add 413 new account codes. Most of the new account codes are associated with ASC Topic 326, Financial Institutions Current Expected Credit Losses, and the new risk-based capital rule, which is scheduled to go into effect on January 1, 2019.

As a result, the total number of account codes in the new prototype Call Report will fall by almost 40 percent to 919.

NCUA will also reorganize Schedules and improve Call Report instructions.

In addition to modernizing its Call Report, NCUA plans to streamline its credit union Profile Form.

NCUA is seeking comments on these proposed changes and poses seven questions for commenters.

Go to NCUA's Call Report Modernization webpage to view proposed changes.

Call Report and Profile slideshow.

Wednesday, January 24, 2018

16 CUs Have Outstanding CDCI Investments at the End of 2017

Sixteen credit unions still have outstanding investments under the Troubled Asset Relief Program's Community Development Capital Initiative (CDCI) at the end of 2017.

The total number of financial institutions with outstanding CDCI investments was 21 on December 31, 2017.

In 2017, six credit unions reported either fully or partially repurchasing their capital investment from the U.S. Treasury.

Tuesday, January 23, 2018

Georgia United Announces Five-Year Sponsorship of UGA Athletics

Georgia United Credit Union (Duluth, GA) announced an expanded five-year sponsorship as the Official Credit Union of Georgia Athletics.

The renewed partnership includes in-venue signage and video features during home football, basketball, baseball and softball games, as well as gymnastics meets. Additional promotional opportunities include radio commercials, in-game features and gymnastics entitlement meets throughout each year.

The price of the sponsorship deal was not disclosed.

Read the press release.

The States of Alaska and Wyoming Are Rural Districts.

In December, the National Credit Union Administration approved two states as rural districts.

NCUA granted Reliant Federal Credit Union (Casper, WY) a community charter for the state of Wyoming. This is the second credit union to be granted Wyoming as a community charter. The other credit union was WYHY Federal Credit Union (Cheyenne, WY), which received a community charter for Wyoming in November.

NCUA also approved the application of Matanuska Valley Federal Credit Union (Palmer, AK) to serve the entire state of Alaska. NCUA determined that Alaska met the requirement for a rural district community charter. The population of the state is less than 1 million and the state's population density of 1.2 people per square mile is below the population density threshold of 100 people per square mile for a rural district. However, it appears that NCUA did not consider the evidence that 66 percent of Alaska's population lives in urban areas.

Read NCUA's December Report of Insurance Activity.

Monday, January 22, 2018

Regulator: Third-Party Risk Management Is A Heightened Supervisory Focus

A bank regulator recently warned that managing third-party risk is a heightened supervisory focus.

The Office of the Comptroller of the Currency (OCC) in its Semiannual Risk Perspective report identified increasing use of third-party service providers and the concentration of critical operations among few service providers as operational concerns.

The report notes a growth in partnerships between banks (you can substitute the term credit unions) and third-party companies or vendors. Financial institutions are becoming more reliant upon third-party financial technology companies for new emerging products and services. This is driving third-party risk.

The report also noted that consolidation -- both among banks and among third-party service providers -- has “increased reliance on a smaller group of third parties providing critical applications and resulted in large numbers of banks, especially community banks, relying on a small number of service providers.”

The report found "instances of concentration of third-party service providers for specialized services, such as merchant card processing, denial-of-service mitigation, ... and other specific product or market service."

This concentration in a limited number of third-party service providers could result in systemic risk in the financial services sector.

The OCC advised that banks address third-party risk "through appropriate due diligence and ongoing oversight."

This should be the same advice to credit unions from the National Credit Union Administration (NCUA), as NCUA does not have the authority to examine third-party service providers, unlike other federal banking regulators.

Friday, January 19, 2018

Wings Financial CU Buys Three Branches and Depositors from Minnesota Bank

Wings Financial Credit Union (Apple Valley, MN) has agreed to purchase three branches from KleinBank (Chaska, MN).

As part of the deal, the credit union will buy branches in the Minnesota communities of Coon Rapids, Otsego and Plymouth. In addition, 4,500 customer of KleinBank will become members of the credit union.

Roughly $40 million in deposits and $10 million in loans will be transferred to Wings Financial.

Wings Financial did not disclose the price of the deal, which is expected to close in the second quarter.

Read the story.

Thursday, January 18, 2018

Credit Unions Have Tapped Taxpayers' Funds

Credit unions have received taxpayer money, despite statements to the contrary.

Recently, Richard T. Webb wrote Credit Union Times that "[c]redit unions have never cost the tax payers [sic] a single penny and will not going forward."

The comment was made with respect to credit unions being subject to the Consumer Financial Protection Bureau (CFPB) and the controversy over CFPB leadership.

However, this statement fails to take into consideration that credit unions have been beneficiaries of Congressional appropriations.

For example, credit unions can receive funds from the National Credit Union Administration's Community Development Revolving Loan Fund and the U.S. Treasury's Community Development Financial Institution (CDFI) Fund. For example, 56 credit unions in 2017 were awarded $39.5 million in CDFI Funds. Both programs receive taxpayer funding from Congress.

In addition, credit unions can receive free office space and services in government facilities (see Section 1770 of the Federal Credit Union Act). This use of free space constitutes a cost to taxpayers.

For example, a December 18, 2017 blog post noted that the National Labor Relations Board (NLRB) provided space and associated services free of charge to the NLRB Federal Credit Union since it was established in 1938 until 2015. A 2008 NLRB Inspector General report found that in calendar year 2007 the agency provided an estimated $88,778 in support to the credit union.

The Government Accountability Office in 1984 wrote that federal agencies may grant administrative leave to federal employees to render limited support and advice to federal credit unions. This means that federal employees can be excused from their official duties without suffering a loss of pay or leave to provide services to credit unions. This administrative leave is a cost to taxpayers.

In 1987, the Government Accountability Office opined that the Internal Revenue Service could purchase an Automatic Teller Machine for a credit union serving the Atlanta Service Center. This is another example of appropriated funds being used to benefit a credit union and its members.

These examples illustrate that credit unions have tapped taxpayers' funds.

This does not count borrowings from the U.S. Treasury by the National Credit Union Administration associated with the failure of corporate credit unions during the financial crisis and recession or credit unions participating in the Community Development Capital Initiative of the Troubled Asset Relief Program.

Wednesday, January 17, 2018

Credit Unions Fund $112.6 Million Biofuel Loan

A consortium of credit unions funded a $112.6 million loan guaranteed by the United States Department of Agriculture to Ryze Renewables Reno, LLC.

The loan will help support the construction of a biorefinery in Storey County, Nevada.

The loan is the largest to date funded by the USDA Rural Development Biorefinery, Renewable Chemical and Bio based Product Manufacturing Assistance Program.

CU Capital Market Solutions (CMS), an Atlanta-based credit union service organization (CUSO), was the lead loan participation agent for the deal. The loan will be serviced by Greater Commercial Lending, a CUSO owned by the $825 million Greater Nevada Credit Union (Carson City, NV).

Jefferson Financial Federal Credit Union (Metarie, LA) was part of the credit union consortium. In 2017, Jefferson Financial received an injection of $12 million in secondary capital.

Given the size of the loan, this loan should be subject to the Shared National Credit program.

Read more.

NYC Taxi Medallions Sold for Under $200,000 at January 16 Auction

There is mounting evidence that taxi medallion prices in New York City are less than $200,000..

Crain's New York Business is reporting that on January 16th, 7 taxi medallions in possession of Aspire Federal Credit Union (Clark, NJ) were sold in auction for less than $200,000.

Crain's New York Business reported that "a stalking-horse bid of $875,000 for a block of five medallions ended up winning. Two additional medallions not included in the bulk sale sold for $189,000 and $199,000."

So at the low end, taxi medallions were valued at $175,000 each.

This is not good news for credit unions that have specialized in taxi medallion loans or participated in New York City taxi medallion loans.

Read the story.

Tuesday, January 16, 2018

CU Tax Subsidy Going to Wealthy Savers

A Winston-Salem (NC) credit union's certificate of deposit promotion targets wealthy savers.

Allegacy Federal Credit Union is advertising in large bold font a seven-month certificate with an annual percentage yield (APY) of 1.15 percent for balances of $250,000 or more.

Buried in the fine print of the advertisement the credit union states that the seven-month certificate is a tiered rate account. The highest rate is only available for savers meeting the highest tier requirement. To get this favorable rate, funds must not come from an existing Allegacy account.

In addition, a minimum deposit of $1,000 is required to open this certificate. Unfortunately, a majority of Americans could not avail themselves of the lowest tiered requirement with an APY of 0.95 percent, because they don't have enough in savings to open the account.

While credit union industry's tax exemption is tied to its public policy mission to meet the financial needs of people of modest or small means, it appears that Allegacy is diverting its tax subsidy to wealthier savers.

This is another illustration that the credit union industry's tax exemption is poorly targeted and is going to people who don't need taxpayer subsidized savings products.

Below is the ad (click on image to enlarge).

Monday, January 15, 2018

Primary Financial Institutions for Retail Customers and Small Businesses

Below is a chart from Raddon that looks at which institutions are the primary financial institutions for retail customers and small businesses.

According to Raddon, 19 percent of retail customers identify credit unions as their primary financial institution; but only 4 percent of small businesses state that credit unions are their primary financial institution.

Sunday, January 14, 2018

NYC Taxi Medallion Sold at Auction for High Bid of $185,000

Recent auctions indicate that New York City (NYC) taxi medallions are valued around $185,000 per medallion.

On January 11th, six NYC taxi medallions in possession of First Jersey Credit Union (Wayne, NJ) were auctioned for a high bid of $185,000 per medallion, according to the president of Maltz Auctions.

This price of $185,000 per medallion is in-line with the value of 46 NYC taxi medallions sold at auction in September 2017 for $186,000 each.

This coming week, more details on the value of NYC taxi medallions will be revealed as nine NYC taxi medallions in possession of Aspire Federal Credit Union (Clark, NJ) will be auctioned on January 16. The minimum opening bid is $150,000 per medallion.

These valuations indicate more pain awaits credit unions that financed taxi medallion loans and higher reserving for losses by the National Credit Union Share Insurance Fund.

Thursday, January 11, 2018

Many Merger Targets Posted Material Jump in Compensation Prior to Merger.

A number of credit unions that were merger targets in recent years reported a material increase in year-over-year quarterly salaries and benefits before their mergers were completed.

Looking at mergers completed between the third quarter of 2014 and third quarter of 2017, 189 credit unions reported at least a 15 percent year-over-year increase in quarterly salaries and benefits. The salary and benefit information is from the quarter or two quarters before the mergers were completed.

Fifty-nine credit unions reported at least a doubling in salaries and benefits.

Below are several examples of material increases in compensation prior to the completion of the merger.

American Federal Credit Union (Mission Hills, CA), which was merged into NuVision on April 1, 2017, reported an 845 percent increase in salaries and benefits at the end of the first quarter of 2017 compared to a year earlier. This material increase in compensation caused the credit union to post a loss of $735,526,

Newport Beach City Employees (Newport Beach, CA), which was acquired by the Credit Union of Southern California on August 7, 2015, reported an 815 percent increase in quarterly salaries and benefits at the end of 2014 compared to the year earlier. The quarterly payment of almost $1.2 million wiped out the credit union's net worth. The last call report filed by the credit union reported a net worth ratio of minus 8.68 percent.

Star Harbor (Rancho Dominique, CA) reported a year-over-year quarterly jump in salaries and benefits of 747 percent. The credit union merged with Financial Partners Credit Union on August 1, 2017. Due to the material increase in salaries and benefits, the credit union on its last call report posted a mid-year loss of $530,552.

Focal Point Federal Credit Union (Syracuse, NY) merged with Empower Federal Credit Union on January 1, 2016. The credit union reported a 424 percent increase in quarterly compensation in the fourth quarter of 2015 compared to the fourth quarter of 2014. The increase in compensation contributed to a loss of approximately $2 million for the fourth quarter of 2015.

Wednesday, January 10, 2018

Financial Trade Groups Support AML Modernization Bill

Twelve financial groups on January 4th thanked Reps. Steve Pearce (R-N.M.) and Blaine Luetkemeyer (R-Mo.) for introducing an anti-money laundering (AML) and counter-terrorist financing modernization bill that will help prevent criminals from using shell companies to hide illicit activity.

The bill would impose a beneficial ownership reporting requirement on closely held, non-public legal entities and provide financial institutions with access to reported information to help them with their customer due diligence compliance efforts.

“Financial institutions should be able to rely on the information reported by businesses to FinCEN, which would, in turn, reduce the reporting burden on those businesses,” the groups said.

The bill also requires the the Treasury Department to set national priorities for the AML/CFT regime; to facilitate information sharing and feedback between financial institutions and law enforcement; and to encourage the use of technology and artificial intelligence within financial institutions' anti-money laundering programs.

Read the letter.

Tuesday, January 9, 2018

CUs Have Significantly Expanded Consumer Credit Since Recession

A chart in today's Wall Street Journal's The Daily Shot shows that outstanding consumer credit at credit unions has significantly increased since the last recession.

Post recession, outstanding consumer credit at credit unions bottomed out at $218.1 billion in March 2011. Since then, outstanding consumer credit is up almost 94 percent to $422.6 billion as of November 2017.

Tax Bill Imposes Excise Tax on Excess Executive Compensation

On December 22, President signed the Tax Cuts and Jobs Act (H.R. 1) into law.

While the legislation preserved the credit union industry's income tax exemption, the legislation will impose an excise tax on excess executive compensation at credit unions and other tax-exempt entities.

Specifically, the Tax Cuts and Jobs Act imposes a 21 percent excise tax on executive remuneration that exceeds $1 million annually. The tax would apply to the compensation paid to the five highest-paid executives at a tax exempt organization, if their compensation exceeds $1 million.

Executive remuneration includes employee total compensation (including benefits, except those to a tax-qualified retirement plan, such as Roth IRA plans and 457(b) deferred compensation plans, and amounts not included in gross income). Non-qualified deferred compensation will be treated as income for the first taxable year when there is no substantial risk of forfeiture.

In addition, the excise tax will be applied to any any excess parachute payment paid by the applicable tax-exempt organization to a covered employee.

This provision in the law is meant to provide parity with for-profit businesses, which cannot deduct more than $1 million in compensation in any taxable year for covered employees.

The employer will be responsible for paying the excise tax.

To promote compliance with the law, the Internal Revenue Service should require federal credit unions to file Form 990s just like other tax-exempt organizations including state chartered credit unions.

Monday, January 8, 2018

Consumer Credit Growth at CUs Slows in November

The Federal Reserve reported on January 8th that outstanding consumer credit at credit unions grew in November, but at a slower pace than October and September.

Outstanding consumer credit increased by $2.4 billion in November to $22.6 billion.

Revolving credit at credit unions increased by approximately $1.1 billion in November to $56.7 billion, while nonrevolving credit grew by $1.3 billion in November to $365.9 billion.

Read the G.19 Report.

Consumers CU Moves Into 92,000 Square-Foot HQ Building

Consumers Credit Union (Kalamazoo, MI) moves into new corporate headquarters building.

The three-story, 92,000-square-foot headquarters is located at a 22-acre site at The Groves Engineering Business Technology Park.

The building has an on-site café, coffee bar, fitness center, fitness and running trail, and expansive outdoor patio for staff. It also includes a glass atrium with a grand staircase.

The new headquarters will house approximately 150 employees.

To accommodate future growth, the building can be expanded to 200,000 square feet.

The cost of the project was not disclosed.

Read the story.

Here is another story.

Friday, January 5, 2018

Idaho Central CU to Pay $10 Million for Naming Rights to University Arena

Idaho Central Credit Union (Chubbuck, ID) will pay a lump sum of $10 million for naming rights to the proposed basketball arena at the University of Idaho.

The proposed 62,000-square-foot, 4,200-seat arena will be called Idaho Central Credit Union Arena.

The naming rights deal is for 35 years.

Read the story.

Georgia's Own CU Puts Name Atop Atlanta Office Tower

Georgia's Own Credit Union (Atlanta, GA) is relocating its headquarters to the 32-story office the tower in downtown Atlanta.

As the building's anchor tenant, the $2.3 billion credit union will put its name atop the office tower.

The office tower was formerly known as the Equitable Tower.

Read the story.

Thursday, January 4, 2018

NCUA Approves Combined Statistical Area that Had Previously Been Rejected by Federal Court

The National Credit Union Administration (NCUA) in October approved a community charter that was previously rejected by a federal district court.

NCUA granted a community charter to New Cumberland Federal Credit Union serving the Combined Statistical Area of Adams, Cumberland, Dauphin, Lebanon, Perry and York Counties in Pennsylvania.

NCUA amended its regulations governing community charters by recognizing that a Combined Statistical Area with a population up to 2.5 million as a de facto well-defined. local community.

The Harrisburg-York-Lebanon Combined Statistical Area is comprised of four metropolitan statistical areas.

New Cumberland FCU had previously been granted this six-county region, but a federal judge in 2008 ruled that this region did not meet the requirement of being a local community.

The federal judge wrote "[t]o a casual observer familiar with central Pennsylvania, it would likely be a remarkable finding that . . . a geographical area of more than 3,000 square miles with a population of over 1.1 million people ... constituted a 'well-defined local community.'"

Wednesday, January 3, 2018

CU Believes It Knows Best, Will Donate 100% of NCUA Dividend to Charities

One Massachusetts credit union is pledging to donate one hundred percent of its National Credit Union Administration dividend from the closure of Temporary Corporate Credit Union Stabilization Fund to local charities and is encouraging other credit unions to do the same.

The National Credit Union Administration anticipates that it will pay a dividend between $600 million and $800 million in 2018 to credit unions.

Members First Credit Union (Marlborough, MA) stated that giving this unexpected windfall to local charities to address critical needs in its community is the best use of these funds.

However, I disagree. This is a classic example of a principal-agent problem.

It appears that credit union management (agent) may be putting its interest ahead of its members (principal).

Rather than giving these funds to charities, the credit union should return these funds to its members.

Let the members determine how they want to allocate these funds. Members may share these funds with charitable organizations; but they could also save it or even spend these funds.

I firmly believe that the credit union members know what is the best use of these funds.

Read the Members First Credit Union press release.

Tuesday, January 2, 2018

NCUA Declares the State of Wyoming a Rural District

In November 2017, the National Credit Union Administration (NCUA) granted WYHY Federal Credit Union (Cheyenne, WY) a community charter serving the entire state of Wyoming as a rural district.

The estimated 2016 population of Wyoming is 585,501.

The credit union was able to add the whole state, because NCUA raised the population threshold for a rural district from 250,000 to 1 million under its new field of membership rule.

However, NCUA is abusing the term rural by stating the whole state of Wyoming is a rural district.

While the population density for the state is approximately 6 people per square mile, more than half of the residents in Wyoming reside in urban areas.

Below is an image of the approval.

Monday, January 1, 2018

Conserved North Dakota CU Merged

Citizens Community Credit Union (Devils Lake, ND) merged with First Community Credit union (Jamestown, ND) on January 1, 2018.

The National Credit Union Administration placed Citizens Community Credit Union into conservatorship on June 23, 2017.

The combined entity will have almost $800 million in assets.

Read the merger FAQ.


The content is provided for educational purposes only, with the understanding that neither the authors, contributors, nor the publishers of this site are engaged in rendering legal, accounting or other expert or professional services. If legal or other expert assistance is required, the services of a competent professional should be sought.

Comments appearing in response to articles appearing on this site do not necessarily reflect the views of the ABA. ABA makes no representations regarding the truth or accuracy of commentary or opinions that may be posted in response to the articles that appear on this website.

The inclusion herein of any link to a website, either in the text of an article or in a comment, does not denote any approval, sponsorship, or endorsement by the ABA, and ABA is not responsible for the content or opinions expressed on those linked websites or related commentary. This content is not licensed to third parties sites and is not affiliated with any third party site. Any reference to the author or this content on any third party site on the Internet is not authorized by the ABA.

It is the policy of the American Bankers Association to comply fully with all antitrust laws. Certain discussions should be considered off-limits, including those that contain competitively sensitive data such as price and cost information, or statements that could be construed as reflecting an attempt or desire to control or influence a particular market or markets. Future pricing or other prospective competitive information should never be shared.