Legal Opinions Regarding Federal Savings Associations

The following list comprises the legal opinions issued prior the Office of Thrift Supervision (OTS) being combined with the Office of the Comptroller of the Currency (OCC)—before July 21, 2011.

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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
10/16/1991	Guaranteeing or providing additional collateral for a loan on behalf of an ESOP
08/13/1991	Guaranteeing or providing additional collateral for a loan on behalf of an ESOP