Hoosier Banker 55 This information is provided for general education purposes and is not intended to be legal advice. Please consult legal counsel for specific guidance as to how this information applies to your institution’s circumstances or situation. 1 See Interagency Guidance Regarding Unfair or Deceptive Credit Practices at: www.federalreserve.gov/newsevents/ pressreleases/files/bcreg20140822a2.pdf 2 16 CFR §§ 444.1 - .5. make the February payment by Feb. 10 to avoid incurring a late fee for the current installment period. The January late charge will remain uncollected until a future payment is made over and above the current installment. It is important to remember that regardless of the changes made by HEA 1136, you must still comply with the language of your loan contracts with the consumer, and with the prohibitions against “pyramiding” late fees under adopted Interagency Guidance1 based on the Federal Trade Commission’s Credit Practices Rule.2 HB 20+ YEAR PARTNERSHIP WITH INDIANA BANKERS ASSOCIATION Years But Who’s Counting? © 2019 Krieg DeVault LLP. This constitutes attorney advertising. Krieg DeVault LLP, Indianapolis, IN, is responsible for this content. Brett J. Ashton Kay Dee Baird John B. Baxter Julia A. Carpenter Lori Jean Michael J. Messaglia James J. Schwabe Robert J. Wild Nicole R. Finelli Michael E. Williams PARTNER PARTNER PARTNER PARTNER PARTNER PARTNER PARTNER ASSOCIATE PARTNER PARTNER 317.238.6291 bashton@kdlegal.com 317.238.6306 kbaird@kdlegal.com 317.238.6311 jbaxter@kdlegal.com 317.238.6273 jcarpenter@kdlegal.com 317.238.6374 nfinelli@kdlegal.com 574.485.2011 ljean@kdlegal.com 317.238.6249 mmessaglia@kdlegal.com 317.238.6298 jschwabe@kdlegal.com 312.235.1119 rwild@kdlegal.com 317.238.6220 mwilliams@kdlegal.com OVER 20 Financial Services Team FUTURE LEADERSHIP DIVISION SPONSOR MEGA CONFERENCE 2019 SPONSOR ANNUAL CONVENTION SPONSOR BANKING ON WOMEN CONFERENCE SPONSOR WOMAN OF THE YEAR AWARD SPONSOR Krieg DeVault LLP has been involved in every major event that has shaped the evolution of Indiana’s financial institutions. In addition to leading commercial and investment banks, our clients include specialty finance companies, insurance carriers and agents, broker-dealers, and investment advisers. www.kriegdevault.com The IBA has discontinued the Compliance Connection assistance program, due to lack of engagement. Specifically, the IBA is no longer fielding questions eligible for response through the Hoosier Banker Compliance Connection column. Please note, however, the following resources: • The Compliance Connection column continues to appear in Hoosier Banker. Topics are addressed at the discretion of the author, rather than in response to member questions. • IBA members are invited to continue to submit compliance questions to the IBA for review. The IBA will respond by suggesting appropriate legal counsel. For questions or more information, please contact Eric Augustus at eaugustus@indianabankers.org, 317-387-9380. Note: Compliance Connection Program Discontinued Advanced Agriculture Credit Conference This conference helps ag lenders prepare for the 2019-20 loan renewal season. Topics include future credit risks, the transitioning of farm operations to the next generation, and the new tax law as it impacts agriculture. Click on the icon at left in HB Digital for more information or to register, or go to: indianabankers.org/calendar-of-events Lafayette SEPT. 45
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