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Legal Opinions Regarding Thrift Savings Associations

Date Legal Opinion
12/19/2008 Status of a Savings and Loan Holding Company Under Section 10(c)(9) of the Home Owners' Loan Act
09/25/2008 Authority of Federal Savings Associations to Accept Public Deposits
08/05/2008 Proposed Discount Program
06/17/2008 Treatment of Certain Preferred Stock under OTS Acquisition of Control Regulations
02/20/2008 Ratings of Structured Finance Transactions
11/28/2006 Permissibility of Securities Clearing Activities and Paying Interest on Free Credit Balances
07/20/2006 Operating Subsidiaries and Most Favored Lender Doctrine
06/23/2006 Pass-Through Investments
06/09/2006 Preemption of State Gift Card Restrictions
05/18/2006 Calculation of HOLA Consumer Loan Limits
03/07/2006 Preemption of Certain Lending-Related Provisions in the Code of Montgomery County, Maryland
03/06/2006 Permissibility of a Federal Savings Association Engaging in Precious Metal Transactions on Behalf of Customers
10/28/2004 Illinois Corporate Fiduciary Act
10/25/2004 Authority of a Federal Savings Association to Perform Banking Activities through Agents Without Regard to State Licensing Requirements
09/17/2004 Location and Exportation Authority
09/17/2004 Voting Requirements for Benefit Plans Implemented After a Minority Stock Issuance in a Mutual Holding company Structure
09/14/2004 Underwriting Authority for Asset-Backed Securities by an Operating Subsidiary
05/26/2004 Retention of Unitary Savings and Loan Holding Company Status During a Multi-Step Acquisition
05/13/2004 Participation in Group Mortgage Guaranty Reinsurance Program
02/09/2004 Commercial Community Development Activities
12/03/2003 Applicability of Holding Company Activity Restrictions Under 10(c) of HOLA
12/02/2003 Alternative Mortgage Transaction Parity Act
11/17/2003 Applicability of SEC Rule 144A to Securities Offerings by Regulated Savings Associations
10/06/2003 Preemption of New York Escrow Account Laws
09/02/2003 Preemption of New Mexico Home Loan Protection Act
07/22/2003 Preemption of New Jersey Predatory Lending Act
05/29/2003 Payment of Interest on Demand Deposits
04/28/2003 Remutualization of Three Tiered Mutual Holding Company
01/30/2003 Preemption of New York Predatory Lending Law
01/21/2003 Preemption of Georgia Fair Lending Act
12/23/2002 Home Owners' Loan Act/Savings Association Powers
12/19/2002 Savings and Loan Holding Companies/Change in Control
10/01/2002 Preemption of California Minimum Payment Statute
06/21/2002 The Rights of Federal Mutual Savings Association Members to Distributions of Capital
06/12/2002 Reverse Mortgages Secured by Ownership Interests in Cooperatives
06/12/2002 Oklahoma Restrictions on Cash Dispensing ATMs
06/10/2002 Authority of An Operating Subsidiary of a Federal Savings Association to Conduct Fiduciary Activities
05/14/2002 Applicability of the Wisconsin Motor Vehicle Consumer Lease Law
03/21/2002 Arizona Credit Card Reporting Requirements
03/15/2002 Interpretation of 12 C.F.R. § 545.121
12/14/2001 Preemption of Iowa Laws Regulating Loan Fees
10/29/2001 Authority of Federal Savings Associations to Underwrite and Deal in Municipal Securities 
09/06/2001 Treatment of ESOP Committee Under OTS Acquisition of Control Regulations
07/31/2001 Application of the Affiliated Transactions Rules to a Proposed Restructuring
06/26/2001 Applicability of State Law to Federal Savings Associations
06/19/2001 Authority of Service Corporations of Federal Savings Associations to Underwrite and Deal in Municipal Securities
06/16/2001 State Credit Card Lending Requirements
05/18/2001 Status of a Savings and Loan Holding Company under Section 10(c)(9) of the Home Owners' Loan Act
05/10/2001 Authority of Directors to Act on Board Resolutions by E-mail
04/11/2001 Permissible Activities of Multiple Savings and Loan Holding Companies Under Section 10(c) of the Home Owners' Loan Act
01/03/2001 Authority to Exercise Trust Powers through an Agency Office
08/01/2000 One Way Sweep Arrangement
07/11/2000 Permissible Activities of Savings and Loan Holding Companies
06/02/2000 Due-On-Sale Regulations - Reverse Mortgage Definition
05/05/2000 Referral Fees
04/21/2000 State Law Limiting Payoff Statement Fees
04/20/2000 Requirement for Prior Notice in Connection with Appointment of Successor Individual Trustees of Trusts
04/03/2000 Currency Exchange Forward Contracts
02/03/2000 Payday Lending Operations
02/01/2000 Exempt Holding Company Status Pursuant to HOLA Section 10(c)(3)
02/01/2000 Foreign Currency Denominated Debt Issuance
01/14/2000 Notice to Establish Operating Subsidiaries
12/07/1999 San Francisco ATM Fee Ordinance
11/22/1999 Preemption of Local ATM Fee Restrictions
07/29/1999 Preemption of State Lender Licensing Laws
07/20/1999 Commercial Community Development Investment
06/08/1999 Exempt Multiple Savings and Loan Holding Companies
05/12/1999 Treatment of Insurance Companies Under 12 U.S.C. Section 1467a(e)(1)(A)(iii)
03/11/1999 Merger of Two Mutual Holding Companies and Two Mid-Tier Stock Holding Companies
03/11/1999 Proposed Mortgage Guaranty Reinsurance Activities Through Reciprocal Insurer
03/10/1999 California Unfair Competition Act
01/15/1999 New York State ATM Safety Act
01/04/1999 Preemption of State Mortgage Lender Licensing Requirements
01/04/1999 Preemption of State Branching Statute
12/22/1998 Massachusetts Electronic Branch Restrictions
12/21/1998 Payment of Finders' Fees for Referral of Trust Business
11/17/1998 Whether State Laws that Require Lenders to pay Interest on Escrow Accounts for Hazard Insurance and Real Estate Taxes are Preempted by Federal Law
11/02/1998 Reinsurance of Private Mortgage Insurance for Loans Originated by Affiliates
10/02/1998 Issuance of Mortgage Loan Performance Guaranties by a Federal Savings Association
10/01/1998 Authority of Federal Savings Associations to Provide Payroll Processing Services
09/24/1998 Abstracts of Legal Opinions for 1998
08/19/1998 Commercial Escrow Accounts
07/30/1998 Mutual Fund Use of Common Corporate Logo
07/01/1998 Preemption of State ATM Restrictions
07/01/1998 Interstate Pre-Need Funeral Trust Services and Fiduciary Activities
05/22/1998 Broker-Dealer Service Corporation's use of Common Corporate Logo 
05/15/1998 Indiana Interest on Lawyer Trust Account
05/11/1998 Federal Preemption - Special Mortgage Recording Tax
04/15/1998 Repurchase and Reverse Repurchase Agreements
03/20/1998 Abstracts of Significant Legal Opinions, 1997
03/02/1998 Permissibility of Sweep Arrangements
10/14/1997 Authority to Purchase Farmer Mac Common Stock
10/08/1997 Special Purpose Credit Programs
09/19/1997 Establishment of Automatic Loan Machines 
09/02/1997 Applicability of Virgin Islands Banking Board Order and Virgin Islands, Licensing Statute
08/25/1997 Preemption of State Law Limiting Discount Points
08/19/1997 New Jersey Licensed Lenders Act
07/18/1997 Performance Notes Transaction 
07/16/1997 Real Estate Brokerage Activities
06/12/1997 Adjustments to Home Loans Indexed to LIBOR
04/14/1997 Banking Services Offered via an Internet Connection
02/10/1997 Alternative Mortgage Transaction Parity Act
12/24/1996 Preemption of State Laws Applicable to Credit Card Transactions
11/27/1996 Fixed-Rate Mortgage Loans with a Default Rate
11/22/1996 Commercial Community Development Investments
10/18/1996 Abstracts of Significant Legal Opinions , 1994-1996
08/29/1996 Authority of Federal Savings Associations to Market and Sell Prepaid Telephone Cards
08/08/1996 Interstate Trust Activities
07/12/1996 Reinsurance and Marketing of Private Mortgage Insurance
06/21/1996 Interstate Marketing of Trust Services
05/03/1996 Authority to Originate Reverse Mortgage Loans with an Equity Share Feature
04/30/1996 Wisconsin Prepayment Penalty Statute
03/28/1996 Neighborhood Housing Services of America ("NHSA") Securities
03/28/1996 Authority to Conduct Interstate Trust Business
02/12/1996 Authority to Sell Credit-Related Insurance
01/26/1996 Usury Preemption/Loans Secured by Timeshare Interests
01/18/1996 Preemption of Colorado Annual Reporting Requirements
12/22/1995 Investment in an Electronic Funds Transfer Network
12/18/1995 Debt Cancellation Contracts
11/22/1995 Authority of a Federal Savings Association with Trust Powers to Contract with an Affiliate for Investment Management and Advisory Services
10/20/1995 Alternative Mortgage Transaction Parity Act
10/17/1995 Authority to Provide Ministerial Support Services as Agent for a Trust Company
10/04/1995 Applicability of Section 23A of the FRA to the Origination and Purchase of Loans of an Affiliate
09/15/1995 Authority to Invest in Stock Corporations Operating EFT Systems
09/08/1995 Applicability of Section 23A of the FRA to Purchases of Mortgages Originated by an Affiliate
08/28/1995 Bank/Thrift Inter-Affiliate Arrangements
08/11/1995 Authority to Offer Foreign Currency Exchange Services
06/26/1995 Application to Acquire Institution and Trust Powers Application
05/10/1995 Foreign Mortgage Lending and Mortgage Consulting Services
05/10/1995 Usury Preemption/Loans Secured by Timeshare Interests
05/10/1995 Community Development Investments; HOLA § 5(c)(3)(B)
05/10/1995 Georgia Residential Mortgage Act
05/05/1995 Application for the Purchase of Certain Assets and the Assumption of Certain Liabilities
05/05/1995 Authority to Provide Trust Services Through an Operating Subsidiary
03/28/1995 Savings and Loan Holding Company Activities; 12 U.S.C. § 1467a(c)(3)(B) 
02/09/1995 Treatment of Voting Stock of Non-Subsidiary Thrift Organizations Held by Companies under Common Control
01/13/1995 Conclusive and Rebuttable Control Determinations Under HOLA § 10(e) and OTS Acquisition of Control Regulations, 12 C.F.R. Part 574
01/10/1995 Authority to Underwrite and Reinsure Credit Insurance Through Operating Subsidiaries
12/30/1994 Inter-Affiliate Banking Arrangements
12/28/1994 Signature Requirements for Consumer Loan Applications
12/19/1994 Status of Automatic Teller Machines 12 C.F.R. §§ 545.92(a), .96 and .141
12/14/1994 Loan Procurement Fees
12/14/1994 Preemption of Virginia Law Regulating Money Order Services of Federal Savings Associations 
12/02/1994 Contribution of Holding Company Stock to Thrift Subsidiary to Facilitate an Acquisition
11/10/1994 Proposed Investments in a Low-Income Housing Tax Credit Partnership
11/01/1994 Re: 12 U.S.C. § 1467(c)(1)(C), (3)(B)
10/18/1994 Status of Wisconsin Law Regarding Consumer Access to Credit Reports
10/17/1994 Direct Sale of Credit Insurance and Fixed-Rate annuities by Federal Savings Associations
10/17/1994 Operating Subsidiaries and Federal Preemption
09/29/1994 Savings Associations May Charge (and Export) Under Home Owners' Loan Act Section 4(g) the Same Credit card fees as are authorized by state law for the most Favored Lender in Whose Place the Savings Association Seeks to Stand
09/13/1994 12 U.S.C. § 1467(c)(1)(C)
07/18/1994 Application of the Real Estate Settlement Procedures Act and the Fair Credit Reporting Act to Operating Subsidiaries as Defined in 12 C.F.R. § 545.81
07/07/1994 Composition of a Class of Voting Stock Under 12 C.F.R. Part 574; Status of a Living Trust under 12 U.S.C. Section 1467a
07/06/1994 Foreign Operating Subsidiaries
06/24/1994 Applicability of the Appraisal Requirements to a Series of Construction Loans on Similar Buildings; 12 C.F.R § 563.170 and Part 564
06/14/1994 OTS Authority To Take Enforcement Action Against Operating Subsidiaries For Violations of the ECOA
06/14/1994 Definition of "Readily Marketable Collateral" under Real Estate Lending Standards; Applicability of Sections 23A and 23B of the Federal Reserve Act to Certain Collateral on Loans Made to Third-Party Purchasers
06/13/1994 Proposed Trust Activities of a Federal Savings Association — Location, Branch and Preemption Issues
06/13/1994 Overseas Agency Offices 
05/19/1994 Request for Interpretive Position under 12 C.F.R. Part 563g Exemption from the Offering Circular Requirements for Re-seals of Shares Acquired Through Employee Benefit Plans
05/16/1994 Authority of Savings Associations to Establish and Operate Mobile Banking Facilities or ATMs
05/11/1994 Continued Effectiveness of Section 408(m) Waiver of Management Interlocks Act Prohibition
05/11/1994 OTS Guide to the Federal Laws and Regulations Governing Community Development Activities of Savings Associations
05/06/1994 Application of Section 23B of the Federal Reserve Act and 12 C.F.R § 563.42 to a Proposed Transaction involving ...
03/25/1994 Authority of Federal Savings Associations To Provide Postal Services 
03/01/1994 Collection of Late Charges on Home Equity Loans
02/14/1994 Proposed Option Agreement Between ... 
02/08/1994 OTS No. 7837 Request for No-Action Position Pursuant to Paragraphs (c)(3), (c)(5) and (c)(7), of rule 14a-8
01/31/1994 Authority of federal savings associations to act as residential mortgage document custodians
01/12/1994 Employees' Credit Union ("Credit Union")
01/07/1994 New SEC Policy Re: Referral Fee Program "No-Action" Letters