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Financial Institutions Position Statements

Financial Institutions Position Statements

Banks

Bank Use of Trade Name and Shared Website
Failure to Comply with Historic Preservation Law Can Cause Major Delays for your Bank
Sale of Debt Cancellation Contracts (DCCs) or Debt Suspension Agreements (DSAs)(06/18/04)
Authority to Offer Indexed Certificates of Deposit (04/07/04)
Creditor-placed Insurance (12/30/03)
Guidance on Institution Offering of Check Protection Programs (12/19/03)
Authority of bank subsidiary to conduct security and investigative services for others (redacted) (issued 3-20-03)
Purchase of Bank Owned Life Insurance (BOLI) (redacted) (issued 3-12-02)
Bank transfer of interest income on consumer credit to participating bank subsidiary (redacted) (issued 02-28-2002)
Use of the word bank by out-of-state financial conglomerate in advertising corporate and investment banking services in Michigan (redacted) (issued 02-22-2002)
Authority of out-of-state chartered, limited-purpose trust bank to exercise trust powers in Michigan (redacted) (issued 09-19-2001)
Use of "bank" by out-of-state non-depository state-chartered bank in conducting business in Michigan (redacted) (issued 09-12-2001)
Applicability of lending limit to loans to subsidiary (redacted) (10-01-1999)

MBLSLA Exempt Determinations

Applicability of licensing/registration provisions to industrial loan companies (redacted) (issued 10-1-99)
Industrial loan company not exempt from licensure (redacted) (issued 1-5-00)

MBLSLA Prepayment Penalties

Decision on wording:

"to sell their property prior to the expiration of the pre-payment period, then notwithstanding XXXX's ability to call a default for a transfer without our consent, XXXX is still entitled to collect our pre-payment penalty" (redacted) (issued 11-29-99)
Decision on wording:

Decision on wording:

"3% prepayment penalty will be assessed if this loan is paid in full within the first three years of the loan" (redacted) (issued 1-12-00)
Decision on wording:

Usury Statutes

Applicability of usury laws to deposit accounts (redacted) (issued 6-8-99)