These are opinions from the OTS Office of Chief Counsel. Information deleted to protect confidential business information or personal privacy is marked by brackets.
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
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