OFFICE OF THE GENERAL COUNSEL ABA BANKING DOCKET. October 2016

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1 OFFICE OF THE GENERAL COUNSEL ABA BANKING DOCKET October 2016 WHAT'S NEW THIS MONTH ANTITRUST: United States v. American Express Co. (AmEx) -- The Second Circuit unanimously reverses a lower court decision that found AmEx s anti-steering rules violated federal antitrust law. The 3-0 panel rules the lower court's interpretation of market definition incorrectly elevated the interests of the merchants above the cardholders and failed to adequately consider how the anti-steering rules would affect competition. The Second Circuit concludes the plaintiffs did not sufficiently prove that AmEx s non-discriminatory provisions (NDPs) harmed competition by forbidding merchants from suggesting that customers use other cards with lower discount rates. NO-SURCHARGE LAW: Expressions Hair Design v. Schneiderman -- The Supreme Court agrees to examine a three-way circuit split on whether a New York law that prohibits merchants from imposing a surcharge on credit card purchases (no-surcharge law) is an unconstitutional restriction on free speech in violation of the First Amendment. The Second Circuit ruled New York s no-surcharge law is constitutional because it regulates a pricing practice, not speech. Likewise, the Fifth Circuit ruled earlier this year that Texas no- surcharge law is a permissible economic-pricing regulation and does not implicate the free-speech protections of the First Amendment. However, in November 2015, the Eleventh Circuit struck down Florida s no-surcharge law as an unconstitutional abridgment of free speech. WELLS FARGO SETTLEMENT: In re: Wells Fargo Bank, N.A. -- Wells Fargo agrees to pay $185 million to settle a joint investigation by the Consumer Financial Protection Bureau, the Office of the Comptroller of the Currency, and the city of Los Angeles, alleging the bank s employees opened phony customer accounts to achieve sales targets. Wells Fargo customers also file a class action complaint in Utah federal court, alleging the bank s internal policies for cross-selling caused the fraudulent scheme. In addition, former employees file a $2.6 billion proposed class action complaint in Los Angeles County Superior Court, alleging the bank improperly fired or demoted employees for refusing to participate in the fraudulent scheme. The House Financial Services Committee and the Department of Labor open separate investigations examining Wells Fargo s sales practices. PAYDAY LENDING: Consumer Financial Protection Bureau (CFPB) v. CashCall Inc. -- A district court in Los Angeles hands the CFPB a victory against consumer lender CashCall Inc., ruling the lender deceptively collected illegal interest charges on loans issued by tribal payday lender Western Sky Financial. The court finds CashCall was the true lender because it assumed the monetary burden and financial risk of the loans. Thus, state usury laws control instead of tribal law. FAIR DEBT COLLECTION PRACTICES ACT (FDCPA): Marquez v. Weinstein, Pinson & Riley, P.S. - - The Seventh Circuit revives a class action alleging the law firm of Weinstein Pinson & Riley used misleading wording in a debt-collection complaint attempting to collect unpaid student debt. The appeals

2 court determines the validation notice would mislead an unsophisticated consumer regarding the appropriate time and manner for responding to the complaint. ARTICLE III STANDING: Zia v. CitiMortgage -- A district court in Miami dismisses a class action accusing CitiMortgage and Citibank of violating New York law by failing to provide certificates of discharge for customers mortgages in a timely manner. The court rules the plaintiff did not have standing to sue Citi because he did not adequately allege a concrete harm and particularized injury under the Supreme Court s decision in Spokeo Inc. v. Robins. REGIONS BANK SETTLEMENT: In re: Regions Bank -- Regions Bank agrees to pay $52.4 million to settle a joint investigation by the Department of Justice, Department of Housing and Urban Development, and the U.S. Attorney s Office, alleging the bank violated the False Claims Act by knowingly originating and underwriting mortgage loans insured by the Federal Housing Administration without conducting adequate quality control. PNC SETTLEMENT: In re: Community Bank of Northern Virginia Second Mortgage Lending Practices Litigation -- PNC Financial Services Group agrees to pay at least $24 million to settle a class action brought by homeowners alleging that Community Bank of Northern Virginia, which PNC acquired in 2006, charged excessive fees and kicked back money to a mortgage broker for customer referrals. BITCOIN: United States v. Murgio -- A district court in Manhattan, NY rules that bitcoin qualifies as money under federal law. Defendant Anthony Murgio was charged with operating an illegal Bitcoin exchange, but claimed that virtual currency falls outside the scope of federal law prohibiting the operation of an unlicensed money transmitting business. The court disagrees, ruling bitcoins are funds within the plain meaning of the statute because bitcoins are accepted as payment for goods and services and bought directly from an exchange with a bank account. AMICUS BRIEFS FILED BY ABA HOMEOWNERS PROTECTION ACT (HPA): Fried v. JPMorgan Chase & Co. (JPMorgan) -- ABA files an amicus brief in support of JPMorgan s appeal to the Third Circuit, addressing when a lender must terminate private mortgage insurance (PMI) for a modified mortgage under the HPA. The lower court denied JPMorgan s motion to dismiss because the lender used the reappraised value of plaintiff s mortgage property when the loan was modified. United States v. American Express Co. (AmEx) AMEX WINS ANTI-STEERING DECISION IN SECOND CIRCUIT Date: September 26, 2016 Issue: Whether AmEx's anti-steering rules violate Section 1 of the Sherman Act. Case Summary: A three-judge panel of the Second Circuit unanimously reversed a lower court decision that found AmEx s anti-steering rules violated federal antitrust law. In 2010, the Department of Justice (DOJ) and 17 states (plaintiffs) sued AmEx in New York federal court, alleging AmEx s non-discriminatory provisions (NDPs) harmed competition by forbidding merchants from steering customers towards using other cards with lower discount rates (anti-steering rules).

3 Last year, the district court ruled for the plaintiffs, finding AmEx s anti-steering rules violate antitrust law because they prohibited merchants from encouraging their customers to use alternative credit cards that are less expensive. Moreover, the court ruled the anti-steering rules created an incentive for AmEx to charge higher prices to merchants with no counterbalancing benefits. The court entered a permanent injunction to enjoin AmEx from enforcing its NPDs for ten years. However, on appeal, the Second Circuit reversed, finding the district court erred in its analysis of market definition, market power, and the actual adverse effect of the anti-steering rules on competition. First, the Second Circuit found the district court erred in defining the relevant market because the court did not include cardholders in the market definition alongside merchants. The Second Circuit clarified that the district court incorrectly relied on the Second Circuit s market inquiry analysis in United States v. Visa, a case which involved Visa s exclusionary rules. The Second Circuit concluded the Visa case involved a horizontal restraint of trade among competitors, whereas this case involves a vertical restraint in this case. Second, the Second Circuit dismissed the lower court s assertion that AmEx possessed significant market power because it could unilaterally impose price increases on merchants. In the Second Circuit s view, although merchants may desire lower fees, the lower court failed to recognize that those fees are necessary to maintain AmEx s cardholder satisfaction. The Second Circuit concluded that so long as AmEx s market share is derived from cardholder satisfaction, there is no reason to intervene and disturb the present functioning of the payment-card industry... Whatever market power AmEx has appears to be based on its rewards program and perceived prestige... The NDPs protect that program and that prestige." Finally, the Second Circuit ruled the lower court incorrectly elevated the interests of the merchants above the cardholders. The Second Circuit noted that NDPs affect competition both for merchants and cardholders by protecting the significant revenue AmEx obtains from its relatively high merchant fees. The merchant fees in turn fund the benefits AmEx cardholders receive, and those benefits attract cardholders. As a result, the Second Circuit reasoned that AmEx s merchant fee revenue might decrease the number of consumer benefits and the competition among payment-card networks for cardholders. The Second Circuit concluded the plaintiffs did not adequately prove that the NDPs harmed both merchants and cardholders by reducing the quality or quantity of credit card purchases. Bottom Line: The government has not yet indicated whether it will challenge the ruling. Opinion Expressions Hair Design v. Schneiderman SUPREME COURT WILL EXAMINE NO-SURCHARGE LAW Date: September 29, 2016 Issue: Whether a New York statute that prohibits credit card transactions surcharges violates the First Amendment of the U.S. Constitution.

4 Case Summary: The Supreme Court agreed to examine, and hopefully resolve, a three-way circuit split on whether a New York law that prohibits merchants from imposing a surcharge on credit card purchases (no-surcharge law) is an unconstitutional restriction on free speech. A group of merchants filed the lawsuit alleging New York s no-surcharge law violates their First Amendment rights because the statute does not allow them to tell their customers that they are paying more for using credit than for using cash or another payment method. The merchants claimed they would prefer to post only a single price for their goods and services and charge more than that price to credit-card customers. The Manhattan district court held the no-surcharge statute violated the First Amendment because it created a virtually incomprehensible distinction between prohibited surcharges and permissible discounts based on words and labels, rather than economic realities." But on appeal, the Second Circuit reversed, ruling the law does not implicate the First Amendment because it regulates a pricing practice, not speech. The Second Circuit reasoned the law does not prohibit sellers from referring to credit-cash price differentials as credit-card surcharges, or from engaging in advocacy related to credit-card surcharges... It simply prohibits imposing credit-card surcharges. The Second Circuit concluded that because the no-surcharge law only regulates the difference between a seller s sticker price and the ultimate price that it charges to credit-card customers, the particular relationship between the two prices does not regulate speech. Separately, the Fifth Circuit determined earlier this year that Texas's no-surcharge law was a permissible economic-pricing regulation that did not implicate the free-speech protections of the First Amendment. However, in November 2015, the Eleventh Circuit struck down Florida s no-surcharge law as an unconstitutional abridgment of free speech. Bottom Line: Nine states and one commonwealth have enacted no-surcharge laws (California, Colorado, Connecticut, Florida, Kansas, Maine, Massachusetts, Oklahoma, Texas, and Puerto Rico). Order List In re: Wells Fargo Bank, N.A. WELLS FARGO FINED $185M FOR BOGUS ACCOUNTS Date: September 8, 2016 Issue: Wells Fargo s settlement with the Consumer Financial Protection Bureau (CFPB), the Office of the Comptroller of the Currency (OCC), and the city of Los Angeles over allegations its employees opened unauthorized accounts. Case Summary: Wells Fargo agreed to pay $185 million to settle a joint investigation alleging that its employees opened fake accounts in customers names to meet sales targets. The government claimed that thousands of Wells Fargo employees enrolled customers in deposit accounts, credit cards, debit cards, and online banking without their knowledge or consent from May 2011 through July According to Wells Fargo s analysis, employees opened approximately 1.5 million deposit accounts without customers knowledge and generated about $2 million in fees. After opening the deposit accounts, Wells Fargo employees allegedly transferred funds from the customers

5 authorized accounts to temporarily fund the new accounts. As a result, the customers were charged overdraft and late fees when their original accounts were overdrawn or did not have sufficient funds. The government found that Wells Fargo employees opened approximately 565,000 credit cards without customers knowledge and generated more than $400,000 in annual and overdraft fees. According to the government, Wells Fargo employees created fake addresses to enroll consumers in onlinebanking services without their knowledge. The government found that Wells Fargo had incentive compensation programs for its employees that encouraged them to sign up existing clients for deposit accounts, credit cards, debit cards, and online banking, under which the bank did not adequately monitor the implementation of these programs. Under the terms of the settlement, Wells Fargo will pay $100 million to the CFPB, $35 million to the OCC, and $50 million to Los Angeles. Wells Fargo also agreed to pay full refunds to customers and hire an independent consultant to review the bank s sales practices. Wells Fargo did not admit any wrongdoing in the settlement; however, the bank terminated 5,300 employees for improper sales practices. In the wake of the settlement, Wells Fargo s customers filed a class-action complaint in Utah federal court, alleging the bank s internal policies for cross-selling caused the fraudulent scheme. Former employees also filed a $2.6 billion proposed class action complaint in Los Angeles County Superior Court, alleging the bank improperly fired or demoted employees for refusing to participate in the fraudulent scheme. Furthermore, the House Financial Services Committee and the Department of Labor opened separate investigations into Wells Fargo s sales practices. Bottom Line: Wells Fargo announced that it will eliminate cross-selling goals for its retail banking unit starting in October Consent Order Consumer Financial Protection Bureau (CFPB) v. CashCall Inc. CFPB WINS CASHCALL LAWSUIT Date: September 1, 2016 Issue: Whether CashCall Inc. is the true lender for loans issued by tribal payday lender Western Sky Financial. Case Summary: A district court in Los Angeles granted the CFPB s motion for summary judgment on liability against consumer lender CashCall, ruling the lender deceptively collected illegal interest charges on loans issued by tribal payday lender Western Sky Financial, an online lender owned by a member of the Cheyenne River Sioux Tribe. The CFPB sued CashCall, its affiliated entities, and CashCall s CEO in December 2013, alleging the companies engaged in unfair, deceptive and abuse acts (UDAAP) by collecting payday loans with interest rates above the usury caps in the borrowers home states. According to the CFPB, CashCall s subsidiary, WS Funding LLC, funded the loans issued through Western Sky, and then purchased them back and used CashCall and Delbert Services Corp. to collect on them. The CFPB alleged the loans marketed and serviced by CashCall were usurious in 16 states. CashCall contended it was not the originator of the loans, but instead had a contractual relationship with Western Sky who acted as the nominal lender. The loan agreements included a choice-of-law provision

6 that stated the law of the Cheyenne River Sioux Tribe applies to the loans. CashCall asserted the choice-of-law provision foreclosed the state law usury caps. The district court granted the CFPB s motion for summary judgment, ruling that CashCall was the true lender because it assumed the monetary burden and financial risk of the loans and therefore had the predominant economic interest. Specifically, the court found that CashCall (1) funded a reserve account to fund two days worth of loans; (2) purchased all of Western Sky s loans after a three-day holding period and before any consumer payments were made on the loans; and (3) agreed to indemnify Western Sky for any liability arising from the loans. The court rejected the choice-of-law provision for the Cheyenne River Sioux Tribe, holding the loans were void under the usury and consumer protection laws of the 16 states. The court also held that CashCall s President and CEO was liable because he knew of or was recklessly indifferent to the misrepresentations. Bottom Line: Although the decision is at the district court level, the ruling appears to broaden the CFPB s UDAAP authority to include the enforcement of state interest rate caps. Order Marquez v. Weinstein, Pinson & Riley, P.S. SEVENTH CIRCUIT REVIVES FDCPA CLASS ACTION AGAINST LAW FIRM Date: September 7, 2016 Issue: Whether a debt-collection complaint filed by law firm Weinstein, Pinson & Reiley, P.S. (Weinstein) was misleading and deceptive in violation of the Fair Debt Collection Practices Act (FDCPA). Case Summary: The Seventh Circuit revived a class action alleging that Weinstein used misleading wording in a debt-collection complaint to collect unpaid student debt. The FDCPA requires that collectors send a letter to debtors informing them of their verification rights (validation notice). Plaintiffs filed a class action alleging Weinstein violated the FDCPA by filing a debtcollection complaint that included a misleading and deceptive validation notice on behalf of debt collection agency NCO Financial Systems Inc. Specifically, the plaintiffs claimed the validation notice was unclear as to whether the debt was owed to NCO or Weinstein, under which a paragraph stated: the debt referenced in this suit will be assumed to be valid and correct if not disputed in whole or in part within 30 days." The lower court dismissed the complaint, but on appeal, a three-judge panel of the Seventh Circuit reversed. The Seventh Circuit held that an unsophisticated consumer would find the validation notice difficult to understand with respect to the appropriate time and manner for responding to the complaint. The Seventh Circuit determined the validation notice would mislead an unsophisticated consumer to believe that the debt could only be disputed within the thirty-day period, even though the thirty-day period expired before the answer to the complaint was due. Meaning, the period for disputing the debt was shorter than the period provided by law for the answer. The appeals court also determined the validation notice was misleading because it did not specify who would consider the debt valid at the expiration of the thirty-day period. The court explained that the validation notice differed from Section

7 1692g because it stated that the debt will be considered valid rather than stating that the debt will be considered valid by the debt collector." The Seventh Circuit also dismissed the district court s ruling that the FDCPA should not apply to statements made during litigation. The Seventh Circuit concluded the FDCPA s purpose is to eliminate abusive debt collection practices, and that purpose would be undermined if the FDCPA was inapplicable to communications that occurred in the context of litigation." The Seventh Circuit remanded the case to the district court where the judge will determine whether the paragraph in the validation notice violates the FDCPA. Bottom Line: The Seventh Circuit joins the Second, Third, Tenth, and Eleventh Circuits in holding the FDCPA applies to legal documents. Opinion Zia v. CitiMortgage DISTRICT COURT INTERPRETS SPOKEO DECISION Date: September 26, 2016 Issue: Whether CitiMortgage and Citibank s (Citi) failure to promptly provide certificates of discharge for customers mortgages constitutes a concrete harm to establish Article III standing in light of the Supreme Court s ruling in Spokeo, Inc. v. Robins. Case Summary: A district court in Miami dismissed a class action accusing Citi of violating New York law by failing to provide certificates of discharge for customers mortgages in a timely manner. The court ruled the plaintiff did not have standing to sue Citi under the Supreme Court s decision in Spokeo Inc. v. Robins. The plaintiff secured a mortgage from CitiMortgage and later obtained a home equity line of credit on the same property from Citibank. In 2013, the plaintiff sold the property and used the proceeds to pay off the principal, interest and other amounts due on both loans. In 2015, the plaintiff filed a proposed class action, alleging the companies failed to timely provide certificates of discharge for the mortgages in violation of New York law. The plaintiff contended the New York State Legislature created a statutory right, and that right is sufficient to confer standing. According to the plaintiff, a violation of a statute that grants the right to file suit to collect statutory damages elevates that right to a concrete injury. The district court granted Citi s motion to dismiss, ruling the plaintiff did not have standing to sue under Spokeo because he did not adequately allege a concrete harm and particularized injury. The court decided the plaintiff made no allegations of injury other than a bare procedural violation in which Citi waited too long before filing the documents. For instance, the court explained that the plaintiff did not allege there was a cloud on the title to this property as a result of Citi s failure to timely file these documents or that he was prohibited or deterred from transferring the property. Furthermore, the court emphasized the plaintiff did not identify a tangible or intangible harm that he suffered, other than a delay in recording.

8 In dismissing the plaintiff s argument, the court concluded that if a damages provision was all that was required to confer an injury in fact... Spokeo would be meaningless [because] any legislative body could make an end-run around the strictures of Article III standing by simply including a damages provision in the statute." Bottom Line: This is one of numerous motions filed in district courts throughout the U.S. triggered by the Supreme Court s nebulous Spokeo decision. Order In re: Regions Bank REGIONS BANK FINED $52M FOR RECKLESSLY CERTIFYING FHA MORTGAGES Date: September 8, 2016 Issue: Regions Bank s settlement with the Department of Justice (DOJ), Department of Housing and Urban Development (HUD), and the U.S. Attorney s Office for the Middle District of Florida for alleged False Claims Act violations. Case Summary: Regions Bank agreed to pay $52.4 million to settle allegations that it violated the False Claims Act by knowingly originating and underwriting mortgage loans insured by the Federal Housing Administration (FHA) without conducting adequate quality control. Regions Bank admitted it certified mortgages for FHA insurance that did not meet HUD s underwriting requirements from 2006 until Regions also admitted it did not maintain a quality control (QC) program that fully complied with HUD s requirements during this period. For instance, the government claimed that Region s QC department did not review an adequate sample of FHA loans to ensure compliance. Moreover, Regions employees engaged in a pattern of curing deficiencies during QC review, which resulted in an understated defect rate being reported to senior management. Finally, Regions did not completely adhere to HUD s self-reporting requirements. Bottom Line: While Regions conceded QC deficiencies, the bank did not admit liability as it relates to the charges. Settlement Agreement In re: Community Bank of Northern Virginia Second Mortgage Lending Practices Litigation PNC PAYS $24M TO SETTLE MORTGAGE CLASS ACTION Date: September 12, 2016 Issue: PNC Financial Services Group s (PNC) settlement to resolve a class action alleging violations of the Truth in Lending Act (TILA), Real Estate Settlement Procedures Act (RESPA), and the Racketeer Influenced and Corrupt Organizations Act (RICO).

9 Case Summary: PNC agreed to pay at least $24 million to settle a class action brought by homeowners alleging that Community Bank of Northern Virginia (CBNV), which PNC acquired in 2006, charged excessive fees and kicked back money to a mortgage broker for customer referrals. The complaint alleged that CBNV conspired to generate a high volume of residential second mortgage loans to extract excessive settlement fees. According to the plaintiffs, CBNV did not accurately disclose business arrangements with the unlicensed depository lenders, in which these lenders allegedly solicited borrowers for predatory loans and referred them to CBNV. CBNV then allegedly charged these borrowers for improper title and loan fees, and CBNV used these fees to pay kickbacks. A Pennsylvania federal district court appointed a panel of three arbiters to decide by March 31 whether to ratify PNC s proposed amount of $24 million or the $70 million proposed by the class. The class consists of the 26,698 homeowners who took out a second mortgage with CBNV on their primary residence between May 1998 and December The per-plaintiff payout is estimated to be on average $560 or $1,680, depending on which settlement amount the arbiters choose. Bottom Line: PNC did not admit wrongdoing in the settlement. Notice of Proposed Class Action United States v. Murgio N.Y. DISTRICT COURT RULES BITCOIN IS MONEY Date: September 19, 2016 Issue: Whether bitcoins qualify as funds under federal law. Case Summary: A district court in Manhattan, NY ruled that bitcoin qualifies as money under federal law prohibiting the operation of an unlicensed money transmitting business. Defendant Anthony Murgio was charged with conspiring to operate the website Coin.mx as an unlicensed money transmitting business in violation of Section 1960 of the U.S. Code. According to the government, the website exchange at least $1.8 million for bitcoins on behalf of tens of thousands of customers. In his motion to dismiss, Murgio claimed that virtual currency falls outside the scope of Section 1960 because the statute does not define what constitutes transferring funds. In support of his claim, Murgio argued the court should adopt a narrow definition of funds as found in Black s Law Dictionary, which defines funds as a sum of money established for a particular purpose. Murgio argued that because bitcoin is not money, Section 1960 is rendered inapplicable. However, the district court disagreed, holding bitcoin qualifies as funds under federal law prohibiting the operation of an unlicensed money transmitting business. The court determined that funds means pecuniary resources given its ordinary meaning, and bitcoins fall under this broad category because they are a medium of exchange and a means of payment. Also, the court ruled that bitcoins qualify as money because they can be purchased in exchange for ordinary currency, act as a denominator in value, and are used to conduct financial transactions. Bottom Line: The court s decision is consistent with several other federal court decisions. However, in at least two other cases, the court refused to qualify bitcoins as money. In July, a Florida state court held

10 that bitcoins do not meet the definition of financial transaction; in February, a federal bankruptcy judge ruled that bitcoins are not equivalent to dollars under the bankruptcy code. Order Fried v. JPMorgan Chase & Co. ABA FILES AMICUS BRIEF OVER HOMEOWNERS PROTECTION ACT Date: September 28, 2016 Issue: When must a lender terminate private mortgage insurance (PMI) for a modified mortgage under the Homeowners Protection Act (HPA)? Case Summary: ABA filed an amicus brief in support of JPMorgan Chase s (JPMorgan) appeal to the Third Circuit, addressing when a lender must terminate PMI for a modified mortgage under the HPA. The plaintiff purchased a home with a loan from JPMorgan in The plaintiff was required purchase PMI because the loan-to-value (LTV) exceeded 80%. The agreement stipulated the PMI would automatically terminate on March 1, 2016, when the balance of the loan was 78% of the original value of the property. In 2011, the plaintiff modified the loan, after which the loan balance was scheduled to reach 78% of the original value of the property in July However, JPMorgan informed the plaintiff that her PMI would not terminate until 2026 because the property was reappraised during the modification for significantly less than its value at the time of the purchase. Meaning, JPMorgan used the new appraisal value to determine when the PMI would terminate. Plaintiff then filed a putative class action alleging several violations of the HPA. The district court ruled that a lender must rely on a modified mortgage s new amortization schedule while continuing to rely on the home s old value from the time the mortgage was first originated. JPMorgan filed an interlocutory appeal of the district court s order. ABA argued the district court s ruling conflicts with Fannie Mae and Freddie Mac requirements and ignores general industry practices regarding lenders obligations to terminate PMI for modified mortgages under the HPA. The brief further asserted the ruling (1) harms consumers directly by preventing them from ending their mortgage insurance earlier than they otherwise should; (2) harms consumers indirectly by making mortgages less liquid; and (3) harms lenders by calling standing sales contracts into doubt. Bottom Line: As of October 3, oral argument is not scheduled. Amicus Brief ABA Members: To unsubscribe and to manage your subscriptions, please visit ABA Bulletins and check or uncheck the appropriate boxes. For other inquiries, please contact ABA s Thomas Pinder at tpinder@aba.com or Andrew Doersam at adoersam@aba.com or phone BANKERS.

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