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Legal Opinions Regarding Thrift Savings Associations

DateLegal Opinion
12/19/2008Status of a Savings and Loan Holding Company Under Section 10(c)(9) of the Home Owners' Loan Act 
09/25/2008Authority of Federal Savings Associations to Accept Public Deposits 
08/05/2008Proposed Discount Program 
06/17/2008Treatment of Certain Preferred Stock under OTS Acquisition of Control Regulations 
02/20/2008Ratings of Structured Finance Transactions 
11/28/2006Permissibility of Securities Clearing Activities and Paying Interest on Free Credit Balances 
07/20/2006Operating Subsidiaries and Most Favored Lender Doctrine 
06/23/2006Pass-Through Investments
06/09/2006Preemption of State Gift Card Restrictions 
05/18/2006Calculation of HOLA Consumer Loan Limits 
03/07/2006Preemption of Certain Lending-Related Provisions in the Code of Montgomery County, Maryland
03/06/2006Permissibility of a Federal Savings Association Engaging in Precious Metal Transactions on Behalf of Customers 
10/28/2004Illinois Corporate Fiduciary Act 
10/25/2004Authority of a Federal Savings Association to Perform Banking Activities through Agents Without Regard to State Licensing Requirements 
09/17/2004Location and Exportation Authority 
09/17/2004Voting Requirements for Benefit Plans Implemented After a Minority Stock Issuance in a Mutual Holding company Structure 
09/14/2004Underwriting Authority for Asset-Backed Securities by an Operating Subsidiary 
05/26/2004Retention of Unitary Savings and Loan Holding Company Status During a Multi-Step Acquisition 
05/13/2004Participation in Group Mortgage Guaranty Reinsurance Program
02/09/2004Commercial Community Development Activities 
12/03/2003Applicability of Holding Company Activity Restrictions Under 10(c) of HOLA 
12/02/2003Alternative Mortgage Transaction Parity Act 
11/17/2003Applicability of SEC Rule 144A to Securities Offerings by Regulated Savings Associations 
10/06/2003Preemption of New York Escrow Account Laws 
09/02/2003Preemption of New Mexico Home Loan Protection Act 
07/22/2003Preemption of New Jersey Predatory Lending Act 
05/29/2003Payment of Interest on Demand Deposits 
04/28/2003Remutualization of Three Tiered Mutual Holding Company 
01/30/2003Preemption of New York Predatory Lending Law 
01/21/2003Preemption of Georgia Fair Lending Act 
12/23/2002Home Owners' Loan Act/Savings Association Powers 
12/19/2002Savings and Loan Holding Companies/Change in Control 
10/01/2002Preemption of California Minimum Payment Statute 
06/21/2002The Rights of Federal Mutual Savings Association Members to Distributions of Capital 
06/12/2002Reverse Mortgages Secured by Ownership Interests in Cooperatives 
06/12/2002Oklahoma Restrictions on Cash Dispensing ATMs 
06/10/2002Authority of An Operating Subsidiary of a Federal Savings Association to Conduct Fiduciary Activities 
05/14/2002Applicability of the Wisconsin Motor Vehicle Consumer Lease Law
03/21/2002Arizona Credit Card Reporting Requirements 
03/15/2002Interpretation of 12 C.F.R. § 545.121 
12/14/2001Preemption of Iowa Laws Regulating Loan Fees 
10/29/2001Authority of Federal Savings Associations to Underwrite and Deal in Municipal Securities 
09/06/2001Treatment of ESOP Committee Under OTS Acquisition of Control Regulations
07/31/2001Application of the Affiliated Transactions Rules to a Proposed Restructuring 
06/26/2001Applicability of State Law to Federal Savings Associations 
06/19/2001Authority of Service Corporations of Federal Savings Associations to Underwrite and Deal in Municipal Securities 
06/16/2001State Credit Card Lending Requirements 
05/18/2001Status of a Savings and Loan Holding Company under Section 10(c)(9) of the Home Owners' Loan Act 
05/10/2001Authority of Directors to Act on Board Resolutions by E-mail 
04/11/2001Permissible Activities of Multiple Savings and Loan Holding Companies Under Section 10(c) of the Home Owners' Loan Act 
01/03/2001Authority to Exercise Trust Powers through an Agency Office 
08/01/2000One Way Sweep Arrangement 
07/11/2000Permissible Activities of Savings and Loan Holding Companies
06/02/2000Due-On-Sale Regulations - Reverse Mortgage Definition 
05/05/2000Referral Fees 
04/21/2000State Law Limiting Payoff Statement Fees 
04/20/2000Requirement for Prior Notice in Connection with Appointment of Successor Individual Trustees of Trusts 
04/03/2000Currency Exchange Forward Contracts 
02/03/2000Payday Lending Operations 
02/01/2000Exempt Holding Company Status Pursuant to HOLA Section 10(c)(3)
02/01/2000Foreign Currency Denominated Debt Issuance 
01/14/2000Notice to Establish Operating Subsidiaries 
12/07/1999San Francisco ATM Fee Ordinance 
11/22/1999Preemption of Local ATM Fee Restrictions 
07/29/1999Preemption of State Lender Licensing Laws 
07/20/1999Commercial Community Development Investment 
06/08/1999Exempt Multiple Savings and Loan Holding Companies
05/12/1999Treatment of Insurance Companies Under 12 U.S.C. Section 1467a(e)(1)(A)(iii) 
03/11/1999Merger of Two Mutual Holding Companies and Two Mid-Tier Stock Holding Companies 
03/11/1999Proposed Mortgage Guaranty Reinsurance Activities Through Reciprocal Insurer 
03/10/1999California Unfair Competition Act 
01/15/1999New York State ATM Safety Act 
01/04/1999Preemption of State Mortgage Lender Licensing Requirements 
01/04/1999Preemption of State Branching Statute
12/22/1998Massachusetts Electronic Branch Restrictions 
12/21/1998Payment of Finders' Fees for Referral of Trust Business 
11/17/1998Whether State Laws that Require Lenders to pay Interest on Escrow Accounts for Hazard Insurance and Real Estate Taxes are Preempted by Federal Law 
11/02/1998Reinsurance of Private Mortgage Insurance for Loans Originated by Affiliates 
10/02/1998Issuance of Mortgage Loan Performance Guaranties by a Federal Savings Association 
10/01/1998Authority of Federal Savings Associations to Provide Payroll Processing Services 
09/24/1998Abstracts of Legal Opinions for 1998 
08/19/1998Commercial Escrow Accounts
07/30/1998Mutual Fund Use of Common Corporate Logo 
07/01/1998Preemption of State ATM Restrictions 
07/01/1998Interstate Pre-Need Funeral Trust Services and Fiduciary Activities 
05/22/1998Broker-Dealer Service Corporation's use of Common Corporate Logo 
05/15/1998Indiana Interest on Lawyer Trust Account 
05/11/1998Federal Preemption - Special Mortgage Recording Tax 
04/15/1998Repurchase and Reverse Repurchase Agreements 
03/20/1998Abstracts of Significant Legal Opinions, 1997
03/02/1998Permissibility of Sweep Arrangements 
10/14/1997Authority to Purchase Farmer Mac Common Stock
10/08/1997Special Purpose Credit Programs
09/19/1997Establishment of Automatic Loan Machines 
09/02/1997Applicability of Virgin Islands Banking Board Order and Virgin Islands, Licensing Statute 
08/25/1997Preemption of State Law Limiting Discount Points 
08/19/1997New Jersey Licensed Lenders Act 
07/18/1997Performance Notes Transaction 
07/16/1997Real Estate Brokerage Activities
06/12/1997Adjustments to Home Loans Indexed to LIBOR 
04/14/1997Banking Services Offered via an Internet Connection 
02/10/1997Alternative Mortgage Transaction Parity Act
12/24/1996Preemption of State Laws Applicable to Credit Card Transactions 
11/27/1996Fixed-Rate Mortgage Loans with a Default Rate 
11/22/1996Commercial Community Development Investments 
10/18/1996Abstracts of Significant Legal Opinions , 1994-1996 
08/29/1996Authority of Federal Savings Associations to Market and Sell Prepaid Telephone Cards
08/08/1996Interstate Trust Activities
07/12/1996Reinsurance and Marketing of Private Mortgage Insurance
06/21/1996Interstate Marketing of Trust Services
05/03/1996Authority to Originate Reverse Mortgage Loans with an Equity Share Feature 
04/30/1996Wisconsin Prepayment Penalty Statute
03/28/1996Neighborhood Housing Services of America ("NHSA") Securities 
03/28/1996Authority to Conduct Interstate Trust Business 
02/12/1996Authority to Sell Credit-Related Insurance 
01/26/1996Usury Preemption/Loans Secured by Timeshare Interests 
01/18/1996Preemption of Colorado Annual Reporting Requirements 
12/22/1995Debt Cancellation Contracts
12/18/1995Debt Cancellation Contracts 
11/22/1995Authority of a Federal Savings Association with Trust Powers to Contract with an Affiliate for Investment Management and Advisory Services
10/20/1995Alternative Mortgage Transaction Parity Act
10/17/1995Authority to Provide Ministerial Support Services as Agent for a Trust Company 
10/04/1995Applicability of Section 23A of the FRA to the Origination and Purchase of Loans of an Affiliate 
09/15/1995Authority to Invest in Stock Corporations Operating EFT Systems
09/08/1995Applicability of Section 23A of the FRA to Purchases of Mortgages Originated by an Affiliate 
08/28/1995Bank/Thrift Inter-Affiliate Arrangements 
08/11/1995Authority to Offer Foreign Currency Exchange Services
06/26/1995Application to Acquire Institution and Trust Powers Application 
05/10/1995Foreign Mortgage Lending and Mortgage Consulting Services 
05/10/1995Usury Preemption/Loans Secured by Timeshare Interests 
05/10/1995Community Development Investments; HOLA § 5(c)(3)(B) 
05/10/1995Georgia Residential Mortgage Act
05/05/1995Application for the Purchase of Certain Assets and the Assumption of Certain Liabilities 
05/05/1995Authority to Provide Trust Services Through an Operating Subsidiary 
03/28/1995Savings and Loan Holding Company Activities; 12 U.S.C. § 1467a(c)(3)(B) 
02/09/1995Treatment of Voting Stock of Non-Subsidiary Thrift Organizations Held by Companies under Common Control
01/13/1995Conclusive and Rebuttable Control Determinations Under HOLA § 10(e) and OTS Acquisition of Control Regulations, 12 C.F.R. Part 574
01/10/1995Authority to Underwrite and Reinsure Credit Insurance Through Operating Subsidiaries
12/30/1994Inter-Affiliate Banking Arrangements 
12/28/1994Signature Requirements for Consumer Loan Applications 
12/19/1994Status of Automatic Teller Machines 12 C.F.R. §§ 545.92(a), .96 and .141 
12/14/1994Loan Procurement Fees
12/14/1994Preemption of Virginia Law Regulating Money Order Services of Federal Savings Associations 
12/02/1994Contribution of Holding Company Stock to Thrift Subsidiary to Facilitate an Acquisition 
11/10/1994Proposed Investments in a Low-Income Housing Tax Credit Partnership 
11/01/1994Re: 12 U.S.C. § 1467(c)(1)(C), (3)(B) 
10/18/1994Status of Wisconsin Law Regarding Consumer Access to Credit Reports
10/17/1994Direct Sale of Credit Insurance and Fixed-Rate annuities by Federal Savings Associations 
10/17/1994Operating Subsidiaries and Federal Preemption 
09/29/1994Savings 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 
09/13/199412 U.S.C. § 1467(c)(1)(C) 
07/18/1994Application 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 
07/07/1994Composition 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 
07/06/1994Foreign Operating Subsidiaries 
06/24/1994Applicability of the Appraisal Requirements to a Series of Construction Loans on Similar Buildings; 12 C.F.R § 563.170 and Part 564 
06/14/1994OTS Authority To Take Enforcement Action Against Operating Subsidiaries For Violations of the ECOA 
06/14/1994Definition 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 
06/13/1994Proposed Trust Activities of a Federal Savings Association — Location, Branch and Preemption Issues 
06/13/1994Overseas Agency Offices 
05/19/1994Request 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 
05/16/1994Authority of Savings Associations to Establish and Operate Mobile Banking Facilities or ATMs 
05/11/1994Continued Effectiveness of Section 408(m) Waiver of Management Interlocks Act Prohibition 
05/11/1994OTS Guide to the Federal Laws and Regulations Governing Community Development Activities of Savings Associations 
05/06/1994Application of Section 23B of the Federal Reserve Act and 12 C.F.R § 563.42 to a Proposed Transaction involving ... 
03/25/1994Authority of Federal Savings Associations To Provide Postal Services 
03/01/1994Collection of Late Charges on Home Equity Loans 
02/14/1994Proposed Option Agreement Between ... 
02/08/1994OTS No. 7837 Request for No-Action Position Pursuant to Paragraphs (c)(3), (c)(5) and (c)(7), of rule 14a-8 
01/31/1994Authority of federal savings associations to act as residential mortgage document custodians 
01/12/1994Employees' Credit Union ("Credit Union") 
01/07/1994New SEC Policy Re: Referral Fee Program "No-Action" Letters