Office of Thrift Supervision

Legal Opinions

OTS Is Now Part of the Office of the Comptroller of the Currency

NOTE: These are opinions from the OTS Office of Chief Counsel issued prior to July 21, 2011. For opinions issued on or after July 21, 2011, regarding thrift savings associations see the OCC Interpretations and Precedents page.

OCC Interpretations and Precedents
www.occ.gov/topics/laws-regulations/interpretations-and...

Legal Opinions

09/08/95 -

Applicability of Section 23A of the FRA to Purchases of Mortgages Originated by an Affiliate
08/28/95 -

Bank/Thrift Inter-Affiliate Arrangements
08/11/95 -

Authority to Offer Foreign Currency Exchange Services
06/26/95 -

Application to Acquire Institution and Trust Powers Application
05/10/95 -

Foreign Mortgage Lending and Mortgage Consulting Services
05/10/95 -

Usury Preemption/Loans Secured by Timeshare Interests
05/10/95 -

Community Development Investments; HOLA § 5(c)(3)(B)
05/10/95 -

Georgia Residential Mortgage Act
05/05/95 -

Application for the Purchase of Certain Assets and the Assumption of Certain Liabilities
05/05/95 -

Authority to Provide Trust Services Through an Operating Subsidiary
03/28/95 -

Savings and Loan Holding Company Activities; 12 U.S.C. § 1467a(c)(3)(B)
02/09/95 -

Treatment of Voting Stock of Non-Subsidiary Thrift Organizations Held by Companies under Common Control
01/13/95 -

Conclusive and Rebuttable Control Determinations Under HOLA § 10(e) and OTS Acquisition of Control Regulations, 12 C.F.R. Part 574
01/10/95 -

Authority to Underwrite and Reinsure Credit Insurance Through Operating Subsidiaries
12/30/94 -

Inter-Affiliate Banking Arrangements
12/28/94 -

Signature Requirements for Consumer Loan Applications
12/19/94 -

Status of Automatic Teller Machines 12 C.F.R. §§ 545.92(a), .96 and .141
12/14/94 -

Loan Procurement Fees
Summary Conclusion: 12 C.F.R. § 563.40(a), which prohibits savings associations from paying loan procurement fees to affiliated persons, does not provide an exception for loan solicitation services (as opposed to loan origination services) actually performed.
Date: December 14, 1994
Subjects: Home Owners' Loan Act/Savings Association Powers, Affiliate Transactions
12/14/94 -

Preemption of Virginia Law Regulation Money Order Services of Federal Savings Associations
12/02/94 -

Contribution of Holding Company Stock to Thrift Subsidiary to Facilitate an Acquisition
11/10/94 -

Proposed Investments in a Low-Income Housing Tax Credit Partnership
11/01/94 -

Re: 12 U.S.C. § 1467(c)(1)(C), (3)(B)
10/18/94 -

Status of Wisconsin Law Regarding Consumer Access to Credit Reports
10/17/94 -

Direct Sale of Credit Insurance and Fixed-Rate annuities by Federal Savings Associations
10/17/94 -

Operating Subsidiaries and Federal Preemption

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OTS Is Now Part of the Office of the Comptroller of the Currency

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