EXCESSIVE AMOUNTS

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					           October 10, 2002                                      MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                                                                                                                                           1
                                              DEFINITIONS OF POSSIBLE PREDATORY PRACTICES

                                                                           EXCESSIVE AMOUNTS
          POSSIBLE                                                                                                                                        RELEVANT REGULATOR
     PREDATORY PRACTICE                                                DEFINITION/APPLICABLE INDUSTRY                                                            COMMENTS
Flipping                              Banks and Other Lenders: Flipping involves frequent, unnecessary refinancing of a loan with no                FRB – Examines bank and bank
                                      benefit to the borrower. Flipping results in higher costs to the borrower because the term of repayment       subsidiaries for flipping of loans,
                                      is repeatedly extended through each refinancing and new upfront fees are often collected. This results        particularly at institutions that market
                                      in more interest being paid than if the borrower had been allowed to pay off each loan separately.            to existing customers.
Excessive fees or other charges       Banks and Other Lenders: Unusually high costs for mortgage or real estate brokers or for settlement           OCC – The OCC examines payday
                                      services (sometimes referred to as ―packing‖) may be added to the loan without being clearly explained        lending particularly in the context of
                                      to the consumer. These fees (often described as "points"), when added to the principal of the loan, can       how a national bank conducts its
                                      add thousands of dollars in unnecessary costs. If the customer does not have the cash to pay these fees       third-party relationships.
                                      when he or she takes out the loan, the lender will add these fees to the amount the customer is
                                      borrowing. Insurance premiums are often among the fees that are financed in the loans.                        NASD – Review of customer confirm
                                                                                                                                                    and other records
                                      Also includes ―payday‖ or ―tax anticipation‖ lending, which involves the advance of funds in return for the
                                      borrower’s post-dated check payable at some point in the future when the borrower receives a payment
                                      from salary, a tax return, or other expected payment.
                                      Securities: Excessive charges such as markups (amount which dealer increases the price of a security
                                      it owns before selling it to a client. Markups are most often associated with stocks that trade over-the-
                                      counter.)
High interest rates                   Banks and Other Lenders: Brokers or lenders may "steer" consumers who qualify for prime loans into            FRB - For example, the FRB takes a
                                      more expensive, subprime loans. Practices such as charging exorbitant fees and interest rates often           closer look when interest rates on a
                                                                                                                                                     st
                                      occur when subprime borrowers are unsure about their credit history and loan eligibility or are unaware       1 lien are higher than 8% over
                                      of mortgage details (balloon payments and prepayment penalties, for example).                                 prime, or when interest rates on a
                                                                                                                                                     nd
                                                                                                                                                    2 lien are higher than 10% over
                                                                                                                                                    prime.




           1
             This chart provides information on possible predatory practices identified by banking, securities and insurance regulators. For example, state and federal
           banking regulators consider ―flipping‖ to be a possible predatory practice and would want securities and/or insurance regulators to share any non-public
           supervisory information (pursuant to an information sharing agreement) they encounter on an exam/investigation of a diverse financial entity with operations that
           involve banking and/or securities and/or insurance. For example, state and federal banking and securities regulators consider excessive fees or other charges to
           be a possible predatory practice and would want banking, securities and/or insurance regulators to share any non-public supervisory information (pursuant to an
           information sharing agreement) they encounter on an exam/investigation of a diverse financial entity with operations that involve banking and/or securities and/or
           insurance.
          October 10, 2002                                         MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                                               DEFINITIONS OF POSSIBLE PREDATORY PRACTICES

                                                                            EXCESSIVE AMOUNTS
           POSSIBLE                                                                                                                                        RELEVANT REGULATOR
     PREDATORY PRACTICE                                                   DEFINITION/APPLICABLE INDUSTRY                                                         COMMENTS
                 2
Balloon payments                       Banks and Other Lenders: Some loans are structured so that after a fairly short amount of time, 5-10           FRB – Compliance review of balloon
                                       years, one very large payment is required to pay off the remainder of the loan. This is known as a             loans and disclosures.
                                       balloon. Balloon loans may make the initial monthly payments very low, but the consumer must
                                       refinance these loans before the "balloon" payment is due, or the consumer will be asked to make a
                                       payment of thousands or hundreds of thousands of dollars. Consumers who are unaware of balloon
                                       payments in their mortgage may later be in danger of foreclosure.
Excessive APRs (annual                 Banks and Other Lenders: The APR is the single most important thing to compare when shopping for               FRB – Regularly reviews Annual
percentage rates)                      a loan. It takes into account not only the interest rate, but also points, mortgage broker fees, and certain   Percentage Rate and Truth-in-
                                       other credit charges the lender requires the borrower to pay, expressed as a yearly rate. Generally, the       Lending disclosures during
                                       lower the APR, the lower the cost of the loan.                                                                 examinations.
                   3
Subprime lending                       Banks and Other Lenders: Subprime lending refers to loan programs geared toward borrowers with                 OCC – The OCC follows the
                                       blemished or limited credit histories. Subprime borrowers typically have credit histories that include         Interagency Expanded Guidance for
                                       payment delinquencies, and possibly more severe problems such as chargeoffs, judgments, or                     Subprime Lending Programs.
                                       bankruptcy. They may also have low credit scores, high debt-to-income ratios, or meet other criteria
                                       such as incomplete credit histories. These loans have a higher risk of default than loans to prime             FDIC, OTS, FRB – At every
                                       borrowers. This lending may be predatory when the monthly payment is higher than the refinanced                Compliance Examination, a fair
                                       contract or is not in the best interest of the consumer.                                                       lending analysis is completed. This
                                                                                                                                                      is done every 1-3 years depending
                                                                                                                                                      on the exam cycle. The exam is
                                                                                                                                                      risk-based, so the examiner will look
                                                                                                                                                      at pricing and fees if the risk factors
                                                                                                                                                      are present. The compliance
                                                                                                                                                      examination also permits review of
                                                                                                                                                      such lending for compliance with a
                                                                                                                                                      wide array of consumer protection
                                                                                                                                                      regulations.
Excessive or unnecessary               Banks and Other Lenders: Some brokers or lenders will add unnecessary insurance to the loan.                   FRB – Reviews credit life provisions
insurance                              Often consumers are not informed that this insurance is optional, and will substantially increase the cost     during examinations.
                                       of the loan. This insurance may be single premium credit insurance (insurance paid in one lump sum to
                                       insure against default on the loan), disability insurance, or life insurance. The insurance may only protect
                                       the consumer against disability or death for 5-7 years, while the loan has a 30-year payback plan. Some
                                       predatory loans have a consumer paying for insurance years after the policy has expired. Such
                                       premiums may also be included in ―packing.‖




          2
              Practice not inherently predatory, but may be misused to become predatory.
          3
              Practice not inherently predatory, but may be misused to become predatory.
                                                                                              2
        October 10, 2002                   MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                                   DEFINITIONS OF POSSIBLE PREDATORY PRACTICES

                                                 EXCESSIVE AMOUNTS
            POSSIBLE                                                                                     RELEVANT REGULATOR
    PREDATORY PRACTICE                        DEFINITION/APPLICABLE INDUSTRY                                   COMMENTS
Excessive insurance rates   Insurance                                                             WI Insurance – For credit health,
                                                                                                  life, property and individual health
                                                                                                  insurance products, rates are
                                                                                                  required to be filed and must meet
                                                                                                  statutory and rule requirements.
                                                                                                  Other items are required to be
                                                                                                  disclosed at the time of application.




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          October 10, 2002                                  MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                                             DEFINITIONS OF POSSIBLE PREDATORY PRACTICES

                                                                       DISCLOSURES
              POSSIBLE
      PREDATORY PRACTICE                                        DEFINITION/APPLICABLE INDUSTRY                      RELEVANT REGULATOR COMMENTS
Inadequate/improper disclosures and      Banks and Other Lenders, Securities, Insurance                            FDIC and FRB– The compliance
making disclosures in a rushed way so                                                                              examination also permits review of such
the borrower does not understand the                                                                               lending for compliance with a wide array
nature of the proposed loan                                                                                        of consumer protection regulations,
                                                                                                                   including the Truth in Lending Act and the
                                                                                                                   Real Estate Settlement Procedures Act
                                                                                                                   disclosure requirements, the FTC Act, fair
                                                                                                                   lending and community reinvestment.
                                                                                                                   Testing is done routinely at each
                                                                                                                   examination during Regulation Z – Truth
                                                                                                                   in Lending, and Real Estate Settlement
                                                                                                                   Procedures Act (RESPA) exams.

                                                                                                                   OCC and FRB – Disclosure is one of the
                                                                                                                   aspects that the OCC examines when it
                                                                                                                   examines national banks’ nondeposit
                                                                                                                   investment product retail sales operations
                                                                                                                   for consistency with the Interagency
                                                                                                                   Statement on Retail Sales of Nondeposit
                                                                                                                   Investment Products, dated February 15,
                                                                                                                   1994.

                                                                                                                   NASD – Review of customer confirm and
                                                                                                                   other records.

                                                                                                                   WI Insurance - Reviewed during market
                                                                                                                   conduct examinations and as part of the
                                                                                                                   investigation of consumer complaints.
Refusing to report complete loan         Banks and Other Lenders
payment experience to credit reporting
agencies




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           October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                                               DEFINITIONS OF POSSIBLE PREDATORY PRACTICES

                                                                                  DISCLOSURES
             POSSIBLE                                                                                                                                      RELEVANT REGULATOR
     PREDATORY PRACTICE                                               DEFINITION/APPLICABLE INDUSTRY                                                               COMMENTS
Material omissions including        Securities: Failing to provide information necessary for a potential investor to make an educated decision        CFTC – While not specifically
failing to disclose or minimizing   about whether to invest including risk disclosure, past violations involving fraud or theft, losses incurred by   defined as a predatory practice, this
risk                                former customers, the effect of currently known news on prices, among other things.                               fraud violation resembles those
                                                                                                                                                      labeled predatory by banking
                                                                                                                                                      agencies.




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           October 10, 2002                                      MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                                              DEFINITIONS OF POSSIBLE PREDATORY PRACTICES

                                                             MISREPRESENTATION/DECEPTION/FRAUD
            POSSIBLE                                                                                                                                    RELEVANT REGULATOR
    PREDATORY PRACTICE                                          DEFINITION/APPLICABLE INDUSTRY                                                                  COMMENTS
Engaging in fraud or deception to   Banks and Other Lenders, Securities, Insurance                                                               FDIC – Reviewed at each examination
conceal the true nature of the                                                                                                                   in some form. If consumer complaints
products, from an unsuspecting                                                                                                                   are received by our Consumer Affairs
or unsophisticated borrower,                                                                                                                     Division, an immediate field investigation
investor, or purchaser.                                                                                                                          can be completed after approval by the
                                                                                                                                                 Regional Director. Consumer
                                                                                                                                                 complaints are also reviewed at each
                                                                                                                                                 exam as a normal exam procedure.

                                                                                                                                                 FRB – Review at examination or when
                                                                                                                                                 complaint is received.

                                                                                                                                                 OCC – The OCC may take enforcement
                                                                                                                                                 action against a national bank under 12
                                                                                                                                                 U.S.C. §1818 for failure to file a
                                                                                                                                                 Suspicious Activity Report on a bank
                                                                                                                                                 insider who engages in fraud. The OCC
                                                                                                                                                 may also take enforcement action
                                                                                                                                                 against bank insiders who engage in
                                                                                                                                                 fraud.
False reports                       Securities: Reporting trading profits or losses to customers that do not accurately reflect actual trading   CFTC – While not specifically defined as
                                    gains and losses                                                                                             a predatory practice, this fraud violation
                                                                                                                                                 resembles those labeled predatory by
                                                                                                                                                 banking agencies
Unauthorized trading                Securities: Establishing and/or liquidating a futures or options contract in a customer’s account without    CFTC – While not specifically defined as
                                    receiving prior instructions or approval from the account owner and without having written power of          a predatory practice, this fraud violation
                                    attorney to make such trading decisions.                                                                     resembles those labeled predatory by
                                                                                                                                                 banking agencies.
Misappropriation                    Banks and Other Lenders: Stealing or converting to one’s own use fees, downpayments, or deposits.            CFTC – While not specifically defined as
                                    Securities: Stealing or converting to ones own use money deposited to trade commodity futures                a predatory practice, this fraud violation
                                    contracts or commodity option contracts.                                                                     resembles those labeled predatory by
                                    Insurance: Stealing or converting to one’s own use insurance premiums.                                       banking agencies.
Unreasonable delays in              Securities
transferring an account to
another broker-dealer




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           October 10, 2002                                 MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                                         DEFINITIONS OF POSSIBLE PREDATORY PRACTICES

                                                        MISREPRESENTATION/DECEPTION/FRAUD
            POSSIBLE                                                                                                                                 RELEVANT REGULATOR
   PREDATORY PRACTICE                                              DEFINITION/APPLICABLE INDUSTRY                                                         COMMENTS
Securities fraud               Securities: Ponzi schemes, offshore financing and banking scams, third world infrastructure financing
                               scams, equipment programs, sale of securities in nonexistent businesses, or businesses that have no
                               legitimate operations.
Broker sales practice abuses   Banks and Other Lenders: Misrepresentation, misappropriation of customer funds, forged                         NASD – Review of customer complaints,
                               documentation.                                                                                                 advertising, sales literature and
                               Securities: Includes misrepresentation, misappropriation of customer fund, unauthorized trading,               correspondence.
                               unauthorized margin trading, excessive trading and flipping.
Microcap stock fraud           Securities: Micro cap refers to a company with a market capitalization of between $50 million to $300
                               million. In a fraudulent scheme, the stock drops because at a certain point the broker and brokerage
                               unload their own portion of shares. As they sell to cash in on the high price, their sales drive down the
                               price. Regulators look at micro caps that don’t regularly trade many shares or are start-up companies
                               with little or no earnings. They generally costs $8 or less on small, loosely regulated exchanges, where it
                               is easier to manipulate their price.
Stock manipulation             Securities: Buying or selling stocks by a person or a group of persons to create abnormal trading
                               condition with an intention to mislead other investors and to make abnormal gains from trading.
Insider trading                Securities: Trading by insiders; or illegal trading by insiders who trade based on insider information.
Misrepresentation              Banks and Other Lenders: Making untrue statements about the cost, terms, or conditions of or eligibility       CFTC – While not specifically defined as
                               for a product, or the legal obligation of the customer.                                                        a predatory practice, this fraud violation
                               Securities: Making untrue statements about past or current trading profits, a broker’s or promoter’s           resembles those labeled predatory by
                               background or trading expertise, the likelihood of realizing profits, the existence of trading accounts, the   banking agencies.
                               location or amount of money held, the ability to minimize losses, among other things.
                               Insurance: Communicating false or misleading information in or related to an insurance contract. Unfair        WI Insurance - Reviewed during
                               delays in claim payments, when an insurer’s liability for payment is unclear.                                  market conduct examinations and as
                                                                                                                                              part of the investigation of consumer
                                                                                                                                              complaints.
Collection practices           Banks and Other Lenders: Aggressive, often abusive, collection practices. High foreclosure rates,              FRB – Collection practices discussed
                               without an economic basis. Aggressive capture of equity by, for example, shifting unsecured debt into          during regular examination.
                               mortgages. Foreclosure abuses, such as pressure to sign deeds in lieu of foreclosure.




                                         DEFINITIONS OF POSSIBLE PREDATORY PRACTICES
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           October 10, 2002                                        MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                                                                                   SUITABILITY
           POSSIBLE                                                                                                                                       RELEVANT REGULATOR
   PREDATORY PRACTICE                                                   DEFINITION/APPLICABLE INDUSTRY                                                            COMMENTS
Lack of suitability                  Banks and Other Lenders: Includes not taking into consideration a customer’s ability to pay vs. size           OCC – National banks that fail to
                                     of loan; sophistication of customer to understand loan terms; recommending unsuitable securities; and          operate their nondeposit investment
                                     equity stripping. Equity stripping involves an unscrupulous lender lending an amount that is more than         product retail sales operations safely
                                     the borrower can financially handle, knowing that the borrower is likely to default. The lender can then       and soundly or that engage in
                                     foreclose and sell the house, stripping the homeowner of all the equity he has earned over the years.          violations of law or regulations will be
                                     Securities: Purchases or sales of securities without regard to appropriateness to the investor’s               subject to the appropriate regulatory
                                     situation, e.g., sales to senior citizens without regard for tax ramifications, costs, risks, liquidity, and   action including enforcement action
                                     maturity dates of securities, i.e., viatical settlements, broker CD’s, limited partnerships and oil and gas    under 12 U.S.C. §1818 and referral
                                     ventures.                                                                                                      to the appropriate licensing body.
                                     Insurance: Sale of product inappropriate for the situation of the purchaser.
Underwriting the loan based on       Banks and Other Lenders                                                                                        FRB – This aspect is considered
the equity in the home without                                                                                                                      when scoping fair lending reviews.
regard to whether the income or
other non-housing assets of the
borrower are sufficient to pay off
the loan.
                      4
Negative amortization                Banks and Other Lenders: Loans that have payment adjustment caps instead of interest rate                      FRB – See above. In addition,
                                     adjustment caps. Most loans are designed to amortize, i.e. reduce, to a zero balance by the end of             reviewed during a compliance review.
                                     their loan term. Therefore each payment contains a portion of interest (primarily interest at the
                                     beginning) and a portion of principal. These loans are referred to as "no negs" or not having the
                                     possibility for negative amortization. Generally, E-Loan recommends these loans over negative
                                     amortization products because of the risks of having the loan principal increase instead of decreasing.




           4
               Practice not inherently predatory, but may be misused to become predatory.
                                                                                               8
          October 10, 2002                                MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                                           DEFINITIONS OF POSSIBLE PREDATORY PRACTICES

                                                                      SUITABILITY
             POSSIBLE                                                                                                  RELEVANT REGULATOR
     PREDATORY PRACTICE                                       DEFINITION/APPLICABLE INDUSTRY                                   COMMENTS
Recommendations of unsuitable      Banks and Other Lenders, Securities, Insurance                                OCC – National banks that fail to
financial products (purchases or                                                                                 operate their nondeposit investment
sales of securities to senior                                                                                    product retail sales operations safely
citizens without regard to tax                                                                                   and soundly or that engage in
ramifications, costs, risks,                                                                                     violations of law or regulations will be
liquidity, and maturity dates of                                                                                 subject to the appropriate regulatory
securities, i.e., viatical                                                                                       action including enforcement action
settlements, broker CDs, limited                                                                                 under 12 U.S.C. §1818 and referral
partnerships and oil and gas                                                                                     to the appropriate licensing body.
ventures).
                                                                                                                 NASD – Review of new account
                                                                                                                 information and customer statements

                                                                                                                 WI Insurance – Reviewed during
                                                                                                                 market conduct examinations and as
                                                                                                                 part of the investigation of consumer
                                                                                                                 complaints.




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          October 10, 2002                                    MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                                           DEFINITIONS OF POSSIBLE PREDATORY PRACTICES

                                                            STEERING/CHURNING/MARKETING
         POSSIBLE                                                                                                                          RELEVANT REGULATOR
 PREDATORY PRACTICE                                          DEFINITION/APPLICABLE INDUSTRY                                                        COMMENTS
Steering                     Banks and Other Lenders: Deliberately putting borrowers with good credit into loans with high interest   FDIC and FRB – This factor is
                             rates and away from more affordable options.                                                             considered as one of the many risks
                                                                                                                                      associated with our Fair Lending
                                                                                                                                      Testing. If there are enough risk
                                                                                                                                      factors present the examiners will
                                                                                                                                      make this one of their focal points.

                                                                                                                                      OCC – Steering may be a violation of
                                                                                                                                      the Equal Credit Opportunity Act or
                                                                                                                                      the Fair Housing Act. They could
                                                                                                                                      result in enforcement actions under
                                                                                                                                      12 U.S.C. §1818 or referral to the
                                                                                                                                      Department of Housing and Urban
                                                                                                                                      Development.
High-pressure marketing      Banks and Other Lenders, Securities, Insurance                                                           FRB – See FDIC comments above.
targeted to vulnerable
populations




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           October 10, 2002                                    MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                                             DEFINITIONS OF POSSIBLE PREDATORY PRACTICES

                                                              STEERING/CHURNING/MARKETING
        POSSIBLE                                                                                                                               RELEVANT REGULATOR
 PREDATORY PRACTICE                                             DEFINITION/APPLICABLE INDUSTRY                                                         COMMENTS
Redlining                     Banks and Other Lenders: The illegal practice of a lending institution denying loans or restricting their   FDIC and FRB – Evidence of this
                              number for certain areas of a community.                                                                    type of discrimination is reviewed for
                              Insurance: Unfair discrimination based not on the risk’s characteristics but on its location. The term is   at each Fair Lending Examination.
                              commonly associated with an insurer’s refusal to consider insuring any home or business within a specific
                              area marked by a line drawn on a map.                                                                       OCC – Evidence of this type of
                                                                                                                                          discrimination is reviewed for at each
                                                                                                                                          Fair Lending Examination. Further,
                                                                                                                                          under the Community Reinvestment
                                                                                                                                          Act, the OCC considers the national
                                                                                                                                          bank’s record of helping to meet the
                                                                                                                                          credit needs of its entire community,
                                                                                                                                          including low- and moderate-income
                                                                                                                                          neighborhoods, in its evaluation of
                                                                                                                                          the bank’s application for new
                                                                                                                                          branches or relocation of an existing
                                                                                                                                          branch, bank mergers and
                                                                                                                                          consolidations, and other corporate
                                                                                                                                          activities.

                                                                                                                                          WI Insurance – Reviewed during
                                                                                                                                          market conduct examinations and as
                                                                                                                                          part of the investigation of consumer
                                                                                                                                          complaints.
Unfair or deceptive           Banks and Other Lenders, Securities, Insurance                                                              OCC – The OCC has taken
advertising                                                                                                                               enforcement action in several cases
                                                                                                                                          where examiners found unfair or
                                                                                                                                          deceptive practices in the bank.

                                                                                                                                          NASD – Reviews of account activity.

                                                                                                                                          WI Insurance – Reviewed during
                                                                                                                                          market conduct examinations and as
                                                                                                                                          part of the investigation of consumer
                                                                                                                                          complaints.




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       October 10, 2002                                    MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                                         DEFINITIONS OF POSSIBLE PREDATORY PRACTICES

                                                          STEERING/CHURNING/MARKETING
        POSSIBLE                                                                                                                              RELEVANT REGULATOR
 PREDATORY PRACTICE                                           DEFINITION/APPLICABLE INDUSTRY                                                          COMMENTS
Churning                  Securities: Trading not in accordance with a customer’s trading objectives and instead initiated for the       CFTC – While not specifically
                          purpose of generating commission income for a registrant having control or de facto control over the trading   defined as a predatory practice, this
                          account.                                                                                                       fraud violation resembles those
                          Insurance: When a marketer induces a policyowner to cash in a policy and buy another, even though              labeled predatory by banking
                          replacing the policy is not in the policyowner’s best interest.                                                agencies.




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           October 10, 2002                                     MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                                             DEFINITIONS OF POSSIBLE PREDATORY PRACTICES

                                                                       STATUTORY VIOLATIONS
           POSSIBLE                                                                                                                              RELEVANT REGULATOR
    PREDATORY PRACTICE                                   DEFINITION/APPLICABLE INDUSTRY                                                                COMMENTS
Violations of the Consumer        Banks and Other Lenders, Securities, Insurance                                                        FDIC, FRB and OCC – This is examined for at
Credit Protection Act and other                                                                                                         each Compliance and Safety & Soundness
statutes                                                                                                                                examination.

                                                                                                                                        MI OFIS – practices under Sec. 204 of Mich.
                                                                                                                                        Uniform Securities Act: Unreasonable delay of
                                                                                                                                        the delivery of securities; representation that
                                                                                                                                        securities will be listed or application for listing
                                                                                                                                        has been made without basis; induced
                                                                                                                                        excessive trading; recommended unsuitable
                                                                                                                                        securities; recommended speculative low priced
                                                                                                                                        securities; conducted unauthorized
                                                                                                                                        transactions; charged customer unfair
                                                                                                                                        commissions, mark-ups and service charges;
                                                                                                                                        charged customer price of security at price not
                                                                                                                                        reasonably related to the market; extended
                                                                                                                                        credit to customer in violation of the Securities
                                                                                                                                        Exchange Act of 1934 or Federal Reserve
                                                                                                                                        Board regulations; sold security without
                                                                                                                                        disclosing that broker-dealer is market maker
                                                                                                                                        and/or holds a substantial position in the
                                                                                                                                        market; borrowed money from a customer; and,
                                                                                                                                        unauthorized use of customer funds.

                                                                                                                                        WI Insurance – Identified through
                                                                                                                                        investigations, consumer complaints and
                                                                                                                                        market conduct examinations.
Charter renting                   Banks and Other Lenders: Occurs when a bank charter with federal preemptive power (either             OCC – Vendors who have targeted national
                                  a state chartered federally insured bank or a national bank) is borrowed by a third party to          banks as a means of marketing abusive
                                  conduct business in the bank’s name so that the third party may avail itself of the benefits of the   products free from state and local consumer
                                  bank charter to export interest rates and, in particular, to avoid state consumer protection laws     protection laws should not automatically
                                  that would be applicable to the business if conducted by the third party directly.                    assume that the benefits of the bank charter will
                                                                                                                                        accrue to them by virtue of such relationships,
                                                                                                                                        or that the OCC will support such a position if
                                                                                                                                        challenges are raised.




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          October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                       REGULATIONS/POLICY STATEMENTS FOR POSSIBLE PREDATORY PRACTICES

                                                                          EXCESSIVE AMOUNTS
                                         5
   POSSIBLE PREDATORY PRACTICE                        BANKS AND OTHER LENDERS                              SECURITIES                                     INSURANCE
Flipping                                        FRB – See Regulation Z –                       MI OFIS – See MCL 451.604(a)(1)
                                                http://www.federalreserve.gov/regulations/r
                                                egref.htm - z
Excessive fees or other charges                 MI OFIS – See Credit Reform Act, MCL
                                                445.1856(4), MCL 445.1857(3)
High Interest Rates                             FRB – See Regulation Z –
                                                http://www.federalreserve.gov/regulations/r
                                                egref.htm - z – Sec. 32

                                                MI OFIS – See Credit Reform Act, MCL
                                                445.1854
                 6
Balloon payments                                FRB – See ―Flipping‖ above.
Excessive APRs (annual percentage rates)
                 7
Subprime lending                                OCC, FRB, FDIC, OTS – Interagency
                                                Expanded Guidance for Subprime Lending
                                                Programs:
                                                http://www.occ.treas.gov/ftp/release/2001-
                                                12a.pdf or
                                                http://www.federalreserve.gov/boarddocs/S
                                                RLETTERS/2001/sr0104.htm or
                                                http://www.fdic.gov/regulations/laws/rules/5
                                                000-5100.html - 5479 or
                                                http://www.ots.treas.gov/docs/77108.html

                                                OCC - Third-party relationships guidance:
                                                http://www.occ.treas.gov/ftp/release/2001-
                                                92.doc
Excessive or unnecessary insurance              MI OFIS – See MCL 445.1602a                                                               MI OFIS – Misrepresentation prohibited,
                                                                                                                                          including by omission. See MCL 500.2005.
                                                                                                                                          An agent is required to be trustworthy. See
                                                                                                                                          MCL 500.1239.




          5
            See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
          industries.
          6
            Practice not inherently predatory, but may be misused to become predatory.
          7
            Practice not inherently predatory, but may be misused to become predatory.
                                                                                           14
       October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                    REGULATIONS/POLICY STATEMENTS FOR POSSIBLE PREDATORY PRACTICES

                                                                      EXCESSIVE AMOUNTS
                                      8
  POSSIBLE PREDATORY PRACTICE                     BANKS AND OTHER LENDERS                                SECURITIES                                     INSURANCE
Excessive insurance rates                                                                   MI OFIS – See MCL 451.501                     MI OFIS – Property, casualty, individual
                                                                                                                                          health, and credit insurance rates are
                                                                                                                                          regulated. See MCL 500.2109,
                                                                                                                                          500.2242, 500.2403, 500.2603 and
                                                                                                                                          550.613.

                                                                                                                                          WI Insurance – Licensed companies
                                                                                                                                          and agents are expected to comply with
                                                                                                                                          existing laws and rules regarding sales
                                                                                                                                          and marketing. Violations are
                                                                                                                                          addressed through administrative
                                                                                                                                          actions. See
                                                                                                                                          Chapter 625 Wis. Stats, Rate
                                                                                                                                          Regulation and s. 628.34, Wis. Stat.,
                                                                                                                                          Unfair Marketing Practices.




       8
         See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
       industries.
                                                                                        15
          October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                       REGULATIONS/POLICY STATEMENTS FOR POSSIBLE PREDATORY PRACTICES

                                                                               DISCLOSURES
                                           9
   POSSIBLE PREDATORY PRACTICE                        BANKS AND OTHER LENDERS                               SECURITIES                                     INSURANCE
Inadequate/improper disclosures and making      OCC - See OCC examination procedures           MI OFIS - See MCL 451.501                     MI OFIS – Misrepresentation prohibited,
disclosures in a rushed way so the borrower     at:                                                                                          including by omission. See MCL
does not understand the nature of the           http:/home.occ/ftp/bulletin/94-13.pdf.                                                       500.2005. An agent is required to be
proposed loan                                                                                                                                trustworthy. See MCL 500.1239.
                                                FDIC, OTS - Interagency Questions and
                                                Answers Regarding Community                                                                  WI Insurance – Licensed companies
                                                Reinvestment Act:                                                                            and agents are expected to comply with
                                                http://www.fdic.gov/regulations/laws/federal                                                 existing laws and rules regarding sales
                                                /01CRAQAa.pdf or                                                                             and marketing. Violations are
                                                http://www.ots.treas.gov/pagehtml.cfm?cat                                                    addressed through administrative
                                                Number=63                                                                                    actions. See
                                                                                                                                             s. 628.34, Wis. Stat., Unfair Marketing
                                                FRB - Regulation Z, Real Estate                                                              Practices INS 2.07, 2.14, 2.15, 2.16,
                                                Settlement Procedures Act and Regulation                                                     2.17, 3.25, 3.27, 3.39, 3.46, Wis. Adm.
                                                C: Home Mortgage Disclosure:                                                                 Code.
                                                http://www.federalreserve.gov/regulations/ti
                                                tle12/sec203/12cfr203_01.htm

                                                FRB - Regulation G: Disclosure and
                                                Reporting of CRA-Related Agreements:
                                                http://www.federalreserve.gov/regulations/ti
                                                tle12/sec207/12cfr207_01.htm

                                                MI OFIS - See MCL 445.1672(b)
                                                (Mortgage Brokers, Lenders and Servicers
                                                Licensing Act)
Refusing to report complete loan payment
experience to credit reporting agencies
Material omissions including failing to         MI OFIS - See MCL 445.1672(b), (c)             MI OFIS - See MCL 451.501(2)
disclose or minimizing risk                     (Mortgage Brokers, Lenders and Servicers
                                                Licensing Act)




          9
            See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
          industries.
                                                                                           16
           October 10, 2002                                        MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                         REGULATIONS/POLICY STATEMENTS FOR POSSIBLE PREDATORY PRACTICES

                                                             MISREPRESENTATION/DECEPTION/FRAUD
                                           10
   POSSIBLE PREDATORY PRACTICE                          BANKS AND OTHER LENDERS                             SECURITIES                                    INSURANCE
Engaging in fraud or deception to conceal the      OCC - 12 C.F.R. Part 21.11 – Minimum         MI OFIS – See MCL 451.501(3)
true nature of the loan obligation, or ancillary   Security Devices and Procedures,
products, from an unsuspecting or                  Reports of Suspicious Activities, and Bank
unsophisticated borrower                           Secrecy Act Compliance
                                                   http://www.occ.treas.gov/fr/cfrparts/12CF
                                                   R21.htm.

                                                   MI OFIS – See MCL 445.1672(b)
                                                   (Mortgage Brokers, Lenders and
                                                   Servicers Licensing Act)
False reports                                                                                   MI OFIS – See MCL 451.501(2)
Unauthorized trading                                                                            MI OFIS – See MCL 451.604(a)(1)(o)
Misappropriation                                                                                MI OFIS – See MCL 451.604(a)(1)(x)
Unreasonable delays in transferring an                                                          MI OFIS – See MCL 451.604(a)(1)(j)
account to another broker-dealer
Securities fraud                                                                                MI OFIS – See MCL 451.501
Broker sales practice abuses                                                                    MI OFIS – See MCL 451.604(a)(1)(a) –
                                                                                                (z)
Microcap stock fraud                                                                            MI OFIS – See MCL 451.604(a)(1)(n),
                                                                                                451.501
Stock manipulation                                                                              MI OFIS – See MCL 451.501(1), (3)
Insider trading                                                                                 MI OFIS – See MCL 451.501(2)
Misrepresentation                                  MI OFIS – See MCL 445.1672(b)                MI OFIS – See MCL 451.501(2)               MI OFIS – Misrepresentation prohibited,
                                                   (Mortgage Brokers, Lenders and                                                          including by omission. See MCL
                                                   Servicers Licensing Act)                                                                500.2005. An agent is required to be
                                                                                                                                           trustworthy. See MCL 500.1239.

                                                                                                                                           WI Insurance- Licensed companies and
                                                                                                                                           agents are expected to comply with
                                                                                                                                           existing laws and rules regarding sales
                                                                                                                                           and marketing. Violations are addressed
                                                                                                                                           through administrative actions. See s.
                                                                                                                                           628.34, Wis. Stat., Unfair Marketing
                                                                                                                                           Practices INS 2.07, 2.14, 2.15, 2.16, 2.17,
                                                                                                                                           3.25, 3.27, 3.39, 3.46, Wis. Adm. Code.




           10
              See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
           industries.
                                                                                            17
       October 10, 2002                                      MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                    REGULATIONS/POLICY STATEMENTS FOR POSSIBLE PREDATORY PRACTICES

                                                       MISREPRESENTATION/DECEPTION/FRAUD
                                     11
  POSSIBLE PREDATORY PRACTICE                    BANKS AND OTHER LENDERS                                  SECURITIES                                   INSURANCE
Collection practices                        MI OFIS – See MCL 445.252 (Collection                                                        MI OFIS - Misrepresentation prohibited,
                                            Practices Act); MCL 492.114 (Motor                                                           including by omission. See MCL
                                            Vehicle Sales Finance Act)                                                                   500.2005. An agent is required to be
                                                                                                                                         trustworthy. See MCL 500.1239.




       11
         See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
       industries.
                                                                                       18
           October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                        REGULATIONS/POLICY STATEMENTS FOR POSSIBLE PREDATORY PRACTICES

                                                                                 SUITABILITY
                                          12
  POSSIBLE PREDATORY PRACTICE                          BANKS AND OTHER LENDERS                               SECURITIES                                     INSURANCE
Lack of suitability                              OCC - See examination procedures at:           MI OFIS – See MCL 451.604(a)(1)(m)            MI OFIS - Misrepresentation prohibited,
                                                 http:/home.occ/ftp/bulletin/94-13.pdf.                                                       including by omission. See MCL
                                                                                                                                              500.2005. An agent is required to be
                                                                                                                                              trustworthy. See MCL 500.1239.
Underwriting the loan based on the equity in     OCC – See examination procedures at:
the home without regard to whether the           http:/home.occ/ftp/bulletin/94-13.pdf.
income or other non-housing assets of the
borrower are sufficient to pay off the loan.
                      13
Negative amortization                            OCC – See examination procedures at:
                                                 http:/home.occ/ftp/bulletin/94-13.pdf.
Recommendations of unsuitable financial          OCC – See examination procedures at:           MI OFIS – See MCL 451.604(a)(1)(m)            MI OFIS - Misrepresentation prohibited,
products (purchases or sales of securities to    http:/home.occ/ftp/bulletin/94-13.pdf.                                                       including by omission. See MCL
senior citizens without regard to tax                                                                                                         500.2005. An agent is required to be
ramifications, costs, risks, liquidity, and                                                                                                   trustworthy. See MCL 500.1239.
maturity dates of securities, i.e., viatical
settlements, broker CDs, limited partnerships                                                                                                 WI Insurance - Licensed companies
and oil and gas ventures).                                                                                                                    and agents are expected to comply with
                                                                                                                                              existing laws and rules regarding sales
                                                                                                                                              and marketing. Violations are
                                                                                                                                              addressed through administrative
                                                                                                                                              actions. See
                                                                                                                                              s. 628.34, Wis. Stat., Unfair Marketing
                                                                                                                                              Practices INS 2.07, 2.14, 2.15, 2.16,
                                                                                                                                              2.17, 3.25, 3.27, 3.39, 3.46, Wis. Adm.
                                                                                                                                              Code.




           12
              See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
           industries.
           13
              Practice not inherently predatory, but may be misused to become predatory.
                                                                                            19
          October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                       REGULATIONS/POLICY STATEMENTS FOR POSSIBLE PREDATORY PRACTICES

                                                                STEERING/CHURNING/MARKETING
                                         14
  POSSIBLE PREDATORY PRACTICE                         BANKS AND OTHER LENDERS                                SECURITIES                                    INSURANCE
Steering                                        FRB and OCC - See 42 U.S.C. §3601-                                                           WI Insurance – Licensed companies
                                                3619 Civil Rights Act of 1968 (Fair Housing                                                  and agents are expected to comply with
                                                Act); 24 C.F.R. §§100-110 Fair Housing                                                       existing laws and rules regarding sales
                                                Regulation; 15 U.S.C. §§1691 et seq.;                                                        and marketing. Violations are
                                                Equal Credit Opportunity Act 12 C.F.R.                                                       addressed through administrative
                                                Part 202 Equal Credit Opportunity                                                            actions. See s. 628.34, Wis. Stat.,
                                                Regulation (Regulation B). See Fair                                                          Unfair Marketing Practices INS 2.07,
                                                Lending examination procedures:                                                              2.14, 2.15, 2.16, 2.17, 3.25, 3.27, 3.39,
                                                http://home.occ/handbook/fairlep.pdf and                                                     3.46, Wis. Adm. Code.
                                                www.federalreserve.com
High-pressure marketing targeted to             MI OFIS – See MCL 445.903(x)                                                                 MI OFIS – An agent is required to be
vulnerable populations                                                                                                                       trustworthy. See MCL 500.1239.
Redlining                                       OCC – See 12 C.F.R. Part 25. See                                                             MI OFIS – Rating, but not underwriting,
                                                http://home.occ/crainfo.htm.                                                                 by territory is allowed where actuarially
                                                                                                                                             sound. See MCL 500.2027, 500.2111,
                                                MI OFIS – MCL 445.1601 et seq.; R                                                            500.2117 and 500.2118.
                                                445.1101 et. seq. See
                                                http://www.michiganlegislature.org/mileg.as                                                  WI Insurance– Licensed companies
                                                p?page=GetObject&objName=mcl-Act-                                                            and agents are expected to comply with
                                                135-of-1977                                                                                  existing laws and rules regarding unfair
                                                                                                                                             discrimination. Insurers must provide
                                                                                                                                             documentation to support differential
                                                                                                                                             premiums on the basis of classifications
                                                                                                                                             related to the nature and degree of risk
                                                                                                                                             covered or expenses involved.
                                                                                                                                             Violations are addressed through
                                                                                                                                             administrative actions. See s. 628.34,
                                                                                                                                             Wis. Stat., Unfair Marketing Practices.




          14
             See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
          industries.
                                                                                           20
           October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                        REGULATIONS/POLICY STATEMENTS FOR POSSIBLE PREDATORY PRACTICES

                                                                 STEERING/CHURNING/MARKETING
                                          15
  POSSIBLE PREDATORY PRACTICE                          BANKS AND OTHER LENDERS                               SECURITIES                                   INSURANCE
Unfair or deceptive advertising                  OCC – See Advisory Letter 2002-3               MI OFIS – See MCL 451.501, 451.803            MI OFIS – False advertising prohibited.
                                                 Guidance on Unfair or Deceptive Acts or                                                      See MCL 500.2007.
                                                 Practices
                                                 http://www.occ.treas.gov/ftp/advisory/2002-                                                  WI Insurance- Licensed companies
                                                 3.txt                                                                                        and agents are expected to comply with
                                                                                                                                              existing laws and rules regarding sales
                                                 MI OFIS – See MCL 445.903 (Consumer                                                          and marketing. Violations are
                                                 Protection Act); MCL 493.12a (Regulatory                                                     addressed through administrative
                                                 Loan Act); MCL 493.76 (Secondary                                                             actions. See s. 628.34, Wis. Stat.,
                                                 Mortgage Loan Act)                                                                           Unfair Marketing Practices INS 2.07,
                                                                                                                                              2.14, 2.15, 2.16, 2.17, 3.25, 3.27, 3.39,
                                                                                                                                              3.46, Wis. Adm. Code.
Churning                                         FRB and OCC – See 42 U.S.C. §3601-             MI OFIS – See MCL 451.604(a)(1)(1)            MI OFIS – Misrepresentation to induce
                                                 3619 Civil Rights Act of 1968 (Fair Housing                                                  surrender of policy is prohibited. See
                                                 Act); 24 C.F.R. §§100-110 Fair Housing                                                       MCL 500.2005. An agent is required to
                                                 Regulation; 15 U.S.C. §§1691 et seq.;                                                        be trustworthy. See MCL 500.1239.
                                                 Equal Credit Opportunity Act 12 C.F.R.
                                                 Part 202 Equal Credit Opportunity
                                                 Regulation (Regulation B). See Fair
                                                 Lending examination procedures:
                                                 http://home.occ/handbook/fairlep.pdf and
                                                 www.federalreserve.com




           15
              See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
           industries.
                                                                                            21
           October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                        REGULATIONS/POLICY STATEMENTS FOR POSSIBLE PREDATORY PRACTICES

                                                                        STATUTORY VIOLATIONS
                                          16
  POSSIBLE PREDATORY PRACTICE                          BANKS AND OTHER LENDERS                                SECURITIES                                   INSURANCE
Violations of the Consumer Credit Protection     MI OFIS – See MCL 445.903 (Consumer                                                          MI OFIS – The Michigan Consumer
Act and other statutes                           Protection Act); MCL 445.1672 (Mortgage                                                      Protection Act, MCL 445.901, is
                                                 Brokers, Lenders and Servicers Licensing                                                     enforced by the Attorney General. It
                                                 Act); MCL 493.74 and 493.75 (Secondary                                                       does not apply to violations covered by
                                                 Mortgage Loan Act); MCL 487.12304                                                            the Uniform Trade Practice Act, MCL
                                                 (Banking Code); MCL 487.2067 (Consumer                                                       500.2001, which is enforced by OFIS.
                                                 Financial Services Act)
                                                                                                                                              WI Insurance – Licensed companies
                                                                                                                                              and agents are expected to comply with
                                                                                                                                              existing laws and rules regarding sales
                                                                                                                                              and marketing. Violations are
                                                                                                                                              addressed through administrative
                                                                                                                                              actions. See s. 601.64, Wis. Stat.
                                                                                                                                              Enforcement Procedure.
Charter renting                                  OCC – Agencies Urge Banks and Thrifts to
                                                 Evaluate Risks with Vendors Engaged in
                                                 Practices Viewed as Abusive to
                                                 Consumers – OCC Release 2000-88
                                                 http://www.occ.treas.gov/ftp/release/2000-
                                                 88.txt
                                                 Joint Statement
                                                 http://www.occ.treas.gov/ftp/release/2000-
                                                 88a.txt
                                                 Advisory Letter 2000-10
                                                 http://www.occ.treas.gov/ftp/advisory/2000-
                                                 10.txt




           16
              See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
           industries.
                                                                                            22
          October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                                  REMEDIES/ENFORCEMENT FOR POSSIBLE PREDATORY PRACTICES

                                                                         EXCESSIVE AMOUNTS
                                        17
   POSSIBLE PREDATORY PRACTICE                      BANKS AND OTHER LENDERS                                  SECURITIES                                   INSURANCE
Flipping                                        FRB – See Policy Enforcement Guidelines
                                                and Regulations B, Z and X –
                                                www.federalreserve.com.
Excessive fees or other charges                 FRB – See Policy Enforcement Guidelines        NASD – See NASD Sanction Guidelines –
                                                and Regulations B, Z and X –                   http://www.nasd.com/.
                                                www.federalreserve.com.

                                                MI OFIS – See MCL 445.1861, 445.1862
High Interest Rates                             FRB – See Policy Enforcement Guidelines
                                                and Regulations B, Z and X –
                                                www.federalreserve.com.

                                                MI OFIS – See MCL 445.1861, 445.1862
                   18
Balloon payments                                FRB – See Policy Enforcement Guidelines
                                                and Regulations B, Z and X –
                                                www.federalreserve.com.
Excessive APRs (annual percentage rates)        FRB – See Policy Enforcement Guidelines
                                                and Regulations B, Z and X –
                                                www.federalreserve.com.

                                                MI OFIS – See MCL 445.1861, 445.1862
                   19
Subprime lending                                OCC – Many subprime and third party
                                                practices are unsafe and unsound.
                                                National banks that fail to operate safely
                                                and soundly will be subject to the
                                                appropriate regulatory actions including
                                                enforcement action under 12 U.S.C. §1818.

                                                FRB – See Policy Enforcement Guidelines
                                                and Regulations B, Z and X.




          17
             See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
          industries.
          18
             Practice not inherently predatory, but may be misused to become predatory.
          19
             Practice not inherently predatory, but may be misused to become predatory.
                                                                                           23
          October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                                REMEDIES/ENFORCEMENT FOR POSSIBLE PREDATORY PRACTICES

                                                                         EXCESSIVE AMOUNTS
                                         20
  POSSIBLE PREDATORY PRACTICE                       BANKS AND OTHER LENDERS                                  SECURITIES                                    INSURANCE
Excessive or unnecessary insurance              MI OFIS – See MCL 445.1602a (re: P&C                                                         MI OFIS – Fines, cease and desist
                                                on mortgaged real estate)                                                                    orders, and license suspension or
                                                                                                                                             revocation. See MCL 500.1239,
                                                                                                                                             500.1242, 500.1244 and 500.2038.
Excessive insurance rates                                                                                                                    MI OFIS – Excessive rates prohibited.
                                                                                                                                             See MCL 500.2114, 500.2242,
                                                                                                                                             500.2418 and 500.2618.

                                                                                                                                             WI Insurance – Cease and desist
                                                                                                                                             orders, orders to comply, forfeitures,
                                                                                                                                             suspension or revocation of insurance
                                                                                                                                             license.




          20
             See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
          industries.
                                                                                           24
          October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                                REMEDIES/ENFORCEMENT FOR POSSIBLE PREDATORY PRACTICES

                                                                                DISCLOSURES
                                        21
   POSSIBLE PREDATORY PRACTICE                        BANKS AND OTHER LENDERS                                 SECURITIES                                   INSURANCE
Inadequate/improper disclosures and making      OCC – National banks that fail to operate       NASD – See NASD Sanction Guidelines –        MI OFIS – Fines, cease and desist
disclosures in a rushed way so the borrower     their nondeposit investment product retail      http://www.nasd.com/.                        orders, and license suspension or
does not understand the nature of the           sales operations safely and soundly or that                                                  revocation. See MCL 500.1239,
proposed loan                                   engage in violations of law or regulations      MI OFIS – See MCL 451.501                    500.1242, 500.1244 and 500.2038.
                                                will be subject to the appropriate regulatory
                                                action including enforcement action under                                                    WI Insurance – Cease and desist
                                                U.S.C. §1818 and referral the appropriate                                                    orders, orders to comply, forfeitures,
                                                licensing body.                                                                              suspension or revocation of insurance
                                                                                                                                             license.
                                                MI OFIS – See MCL 445.1679 (Mortgage
                                                Brokers, Lenders and Servicers Licensing
                                                Act)
Refusing to report complete loan payment
experience to credit reporting agencies
Material omissions including failing to         MI OFIS – See MCL 445.1679 (Mortgage                                                         MI OFIS – Fines, cease and desist
disclose or minimizing risk                     Brokers, Lenders and Servicers Licensing                                                     orders, and license suspensions or
                                                Act)                                                                                         revocation. See MCL 500.1239,
                                                                                                                                             500.1242, 500.1244 and 500.2038.




          21
             See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
          industries.
                                                                                           25
           October 10, 2002                                        MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                                   REMEDIES/ENFORCEMENT FOR POSSIBLE PREDATORY PRACTICES

                                                             MISREPRESENTATION/DECEPTION/FRAUD
                                           22
   POSSIBLE PREDATORY PRACTICE                          BANKS AND OTHER LENDERS                                 SECURITIES                                  INSURANCE
Engaging in fraud or deception to conceal the      MI OFIS – See MCL 445.1668a, 445.1679
true nature of the loan obligation, or ancillary   (Mortgage Brokers, Lenders and Servicers
products, from an unsuspecting or                  Licensing Act); MCL 493.64a (Secondary
unsophisticated borrower                           Mortgage Loan Act); MCL 493.9c
                                                   (Regulatory Loan Act); MCL 487.2060g
                                                   (Consumer Financial Services Act); MCL
                                                   487.912d (Sale of Checks Act)
False reports
Unauthorized trading
Misappropriation
Unreasonable delays in transferring an
account to another broker-dealer
Securities fraud
Broker sales practice abuses                                                                     NASD – See NASD Sanction Guidelines –
                                                                                                 http://www.nasd.com/.
Microcap stock fraud
Stock manipulation
Insider trading
Misrepresentation                                  OCC – The OCC may take enforcement                                                           MI OFIS- Fines, cease and desist
                                                   action under 12 U.S.C. §1818 for practices                                                   orders, and license suspensions or
                                                   of this nature where the OCC determines                                                      revocation. See MCL 500.1239,
                                                   them to be unfair or deceptive practices in                                                  500.1242, 500.1244 and 500.2038.
                                                   violation of the law.
                                                                                                                                                WI Insurance – Cease and desist
                                                   MI OFIS – See MCL 445.1679 (Mortgage                                                         orders, orders to comply, forfeitures,
                                                   Brokers, Lenders and Servicers Licensing                                                     suspension or revocation of
                                                   Act)                                                                                         insurance license.
Collection practices                               MI OFIS – See MCL 445.256, 445.257
                                                   (Collection Practices Act); MCL 492.137
                                                   (Motor Vehicle Sales Finance Act)




           22
              See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
           industries.
                                                                                            26
           October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                                 REMEDIES/ENFORCEMENT FOR POSSIBLE PREDATORY PRACTICES

                                                                                  SUITABILITY
                                          23
  POSSIBLE PREDATORY PRACTICE                          BANKS AND OTHER LENDERS                                SECURITIES                                   INSURANCE
Lack of suitability                              OCC – National banks that fail to operate                                                    MI OFIS- Fines, cease and desist
                                                 their nondeposit investment product retail                                                   orders, and license suspensions or
                                                 sales operations safely and soundly or that                                                  revocation. See MCL 500.1239,
                                                 engage in violations of law or regulations                                                   500.1242, 500.1244 and 500.2038.
                                                 will be subject to the appropriate regulatory
                                                 action including enforcement action under
                                                 12 U.S.C. §1818 or referral to the
                                                 Department of Housing and Urban
                                                 Development.
Underwriting the loan based on the equity in
the home without regard to whether the
income or other non-housing assets of the
borrower are sufficient to pay off the loan.
                        24
Negative amortization
Recommendations of unsuitable financial                                                          NASD – See NASD Sanction Guidelines –        MI OFIS - MI OFIS- Fines, cease and
products (purchases or sales of securities to                                                    http://www.nasd.com/.                        desist orders, and license suspensions
senior citizens without regard to tax                                                                                                         or revocation. See MCL 500.1239,
ramifications, costs, risks, liquidity, and                                                                                                   500.1242, 500.1244 and 500.2038.
maturity dates of securities, i.e., viatical
settlements, broker CDs, limited partnerships                                                                                                 WI Insurance - Cease and desist
and oil and gas ventures).                                                                                                                    orders, orders to comply, forfeitures,
                                                                                                                                              suspension or revocation of insurance
                                                                                                                                              license.




           23
              See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
           industries.
           24
              Practice not inherently predatory, but may be misused to become predatory.
                                                                                            27
            October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                                  REMEDIES/ENFORCEMENT FOR POSSIBLE PREDATORY PRACTICES

                                                                  STEERING/CHURNING/MARKETING
                                           25
  POSSIBLE PREDATORY PRACTICE                           BANKS AND OTHER LENDERS                                SECURITIES                                   INSURANCE
Steering                                          FRB and OCC – Steering may be a
                                                  violation of the Equal Credit Opportunity
                                                  Act or the Fair Housing Act. They could
                                                  result in enforcement actions under 12
                                                  U.S.C. §1818 or referral to the Department
                                                  of Housing and Urban Development.
High-pressure marketing targeted to               MI OFIS – See MCL 445.907, 445.908                                                           MI OFIS – Fines and license
vulnerable populations                            (Michigan Consumer Protection Act)                                                           suspension or revocation. See MCL
                                                                                                                                               500.1239, 500.1242 and 500.1244.
Redlining                                         OCC – The OCC considers the national                                                         MI OFIS – Fines, cease and desist
                                                  bank’s record of helping to meet the credit                                                  orders, and license suspension or
                                                  needs of its entire community, including                                                     revocation. See MCL 500.2038.
                                                  low- and moderate-income neighborhoods,                                                      Excessive rates prohibited. See MCL
                                                  in its evaluation of the bank’s application                                                  500.2114, 500.2242, 500.2418 and
                                                  for new branches or relocation of an                                                         500.2618.
                                                  existing branch, bank mergers and
                                                  consolidations, and other corporate                                                          WI Insurance - Cease and desist
                                                  activities.                                                                                  orders, orders to comply, forfeitures,
                                                                                                                                               suspension or revocation of insurance
                                                  MI OFIS – See MCL 445.1612.                                                                  license.
Unfair or deceptive advertising                   MI OFIS – See MCL 445.907, 445.908             NASD – See NASD Sanction Guidelines           MI OFIS – Fines, cease and desist
                                                  (Michigan Consumer Protection Act); MCL        at http://www.nasd.com/.                      orders, and license suspension or
                                                  445.1679 (Mortgage Brokers, Lenders and                                                      revocation. See MCL 500.2038.
                                                  Servicers Licensing Act); MCL 493.77                                                         Excessive rates prohibited. See MCL
                                                  (Secondary Mortgage Loan Act)                                                                500.2114, 500.2242, 500.2418 and
                                                                                                                                               500.2618.

                                                                                                                                               WI Insurance - Cease and desist
                                                                                                                                               orders, orders to comply, forfeitures,
                                                                                                                                               suspension or revocation of insurance
                                                                                                                                               license.
Churning                                                                                         MI OFIS – See MCL 451.604(a)(1)               MI OFIS – Fines, cease and desist
                                                                                                                                               orders, and license suspension or
                                                                                                                                               revocation. See MCL 500.1239,
                                                                                                                                               500.1242, 500.1244 and 500.2038.




            25
               See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
            industries.
                                                                                             28
          October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                                 REMEDIES/ENFORCEMENT FOR POSSIBLE PREDATORY PRACTICES

                                                                       STATUTORY VIOLATIONS
                                        26
   POSSIBLE PREDATORY PRACTICE                        BANKS AND OTHER LENDERS                                SECURITIES                                  INSURANCE
Violations of the Consumer Credit Protection    OCC – On a case-by-case basis the OCC                                                        MI OFIS – Civil fines, injunction and
Act and other statutes                          will require corrective action, such as                                                      actual damages. See MCL 445.901 et
                                                reimbursement, reconsideration for credit,                                                   seq.
                                                etc. under both internal and external
                                                policies for taking corrective action.                                                       WI Insurance - Cease and desist
                                                Corrective actions are taken under the                                                       orders, orders to comply, forfeitures,
                                                OCC’s enforcement powers found in 12                                                         suspension or revocation of insurance
                                                U.S.C. §1818.                                                                                license.

                                                MI OFIS – See MCL 445.907, 445.908
                                                (Michigan Consumer Protection Act).
                                                Cease and desist orders, fines, suspension
                                                or revocation of license, prohibition orders.
                                                See MCL 445.1679 (Mortgage Brokers,
                                                Lenders and Servicers Licensing Act);
                                                MCL 493.77 (Secondary Mortgage Loan
                                                Act); MCL 487.12304 (Banking Code);
                                                MCL 493.19 (Regulatory Loan Act); MCL
                                                493.112 (Credit Card Act); MCL 487.915
                                                (Sale of Checks Act); MCL 487.2060f,
                                                487.2070 (Consumer Financial Services).




          26
             See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
          industries.

                                                                                             29
       October 10, 2002                                       MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                             REMEDIES/ENFORCEMENT FOR POSSIBLE PREDATORY PRACTICES

                                                                    STATUTORY VIOLATIONS
                                     27
  POSSIBLE PREDATORY PRACTICE                      BANKS AND OTHER LENDERS                                SECURITIES                                   INSURANCE
Charter renting                              OCC – Orders Eagle to Cease Payday
                                             Lending Program
                                             Release 2002-01
                                             http://www.occ.treas.gov/ftp/release/2002-
                                             01.txt
                                             Fact Sheet: Eagle National Bank Consent
                                             Order
                                             http://www.occ.treas.gov/ftp/release/2002-
                                             01a.txt
                                             Consent Order
                                             http://www.occ.treas.gov/ftp/eas/ea2001-
                                             104/pdf




       27
          See first chart – ―Possible Predatory Practices Identified and Examined/Investigated by Agencies‖- for a definition of each predatory practice and applicable
       industries.

                                                                                          30
October 10, 2002                        MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                                AGENCY ABBREVIATIONS/WEB ADDRESSES

                                         FEDERAL BANKING REGULATORS
           ABBREVIATION                               AGENCY                                       AGENCY WEB ADDRESS
               FDIC                      Federal Deposit Insurance Corporation                             www.fdic.gov
           FRB – Chicago                   Federal Reserve Bank of Chicago                              www.chicagofed.org
                   OCC                     Office of the Comptroller of the Currency                    www.occ.treas.gov
                   OTS                            Office of Thrift Supervision                           www.ots.treas.gov
                                           STATE BANKING REGULATORS
              IL Banking                   Illinois Office of Banks and Real Estate                     www.obre.state.il.us
              IN Banking                 Indiana Department of Financial Institutions                    www.dfi.state.in.us
              IA Banking            Iowa Department of Commerce – Division of Banking                   www.idob.state.ia.us
           MI OFIS Banking           Michigan Office of Financial and Insurance Services               www.michigan.gov/ofis
             WI Banking                Wisconsin Department of Financial Institutions                      www.wdfi.org
                                       FEDERAL SECURITIES REGULATORS
                   CFTC                   Commodity Futures Trading Commission                              www.cftc.gov
                    SEC                  U.S. Securities and Exchange Commission                            www.sec.gov
                   NASD                                    NASD                                            www.nasd.com
                                         STATE SECURITIES REGULATORS
              IL Securities                    Illinois Securities Department                           www.sos.state.il.us
              IN Securities                      Indiana Securities Division                        www.IN.gov/sos/securities
              IA Securities                         Iowa Securities Bureau                      www.iid.state.ia.us/division/securities
           MI OFIS Securities        Michigan Office of Financial and Insurance Services              www.michigan.gov/ofis
             WI Securities        Wisconsin Department of Financial Institutions – Securities        www.wdfi.org/fi/securities
                                         STATE INSURANCE REGULATORS
              IL Insurance                      Illinois Insurance Department                         www.state.il.us./INS
              IN Insurance                     Indiana Insurance Department                             www.IN.gov/idoi
              IA Insurance                         Iowa Division of Insurance                          www.iid.state.ia.us
           MI OFIS Insurance         Michigan Office of Financial and Insurance Services             www.michigan.gov/ofis
             WI Insurance            Wisconsin Office of the Commissioner of Insurance             www.oci.wi.gov/oci_home.htm




                                                                 31
October 10, 2002                     MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                                ENTITIES/ACTIVITIES AGENCIES REGULATE

                                      FEDERAL BANKING REGULATORS
                    AGENCY                                    ENTITIES/ACTIVITIES AGENCY REGULATES
                   FDIC               FDIC-insured state non-member banks; foreign branches of U.S. insured state member banks.
               FRB – Chicago          State member banks; bank holding companies; foreign branches of U.S. national and state
                                      member banks; federal U.S. branches and agencies of foreign banks; state U.S. branches and
                                      agencies of foreign banks; Edge Act Corporations; and Agreement Corporations.
                     OCC              National banks and their subsidiaries and third-party vendors; federal U.S. branches and
                                      agencies of foreign banks; and foreign branches of U.S. national and state member banks.
                      OTS             Insured federal savings associations; insured state savings associations; and savings
                                      association holding companies.
                                       STATE BANKING REGULATORS
                   IL Banking         State-chartered banks and thrifts; corporate fiduciaries; real estate brokers and agents;
                                      appraisers; timeshare/land sales; mortgage bankers and brokers; leasing agents; check
                                      printers; pawnbrokers; and auctioneers.
                   IN Banking         State-chartered commercial banks; trust companies; savings banks; building and loans
                                      associations; credit unions; pawnbrokers; money transmitters; industrial loan and investment
                                      companies; budget service companies; rental/purchase businesses; check cashers; and
                                      licensees under the Uniform Consumer Credit Code.
                   IA Banking         State-chartered banks; bank holding companies; trust operations; regulated loan companies;
                                      industrial loan companies; debt management companies; mortgage bankers/brokers; delayed
                                      deposit services (payday lenders); and money transmitters.
              MI OFIS Banking         State-chartered banks; banks/savings banks authorized to exercise trust powers; business and
                                      industrial development companies; denovo banks; consumer financial service licensees; credit
                                      card licensees; motor vehicle installment seller licensees; motor vehicle sales finance
                                      licensees; regulatory loan licensees; sale of check licensees; active state-chartered credit
                                      unions; mortgage licensees/registrants.
                   WI Banking         State-chartered banks; state-chartered credit unions; businesses engaging in various financial
                                      endeavors, such as adjustment service companies, currency exchanges, collection agencies,
                                      insurance premium finance companies, loan companies, sales finance companies, sellers of
                                      checks, mortgage banking, savings and loans, and savings banks.




                                                          32
October 10, 2002                 MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                            ENTITIES/ACTIVITIES AGENCIES REGULATE

                                 FEDERAL SECURITIES REGULATORS
                   AGENCY                                  ENTITIES/ACTIVITIES AGENCY REGULATES
                   CFTC           Regulates commodity futures and option markets in the United States and protects market
                                  participants against manipulation, abusive trade practices and fraud. A futures contract is an
                                  agreement to buy or sell in the future a specific quantity of a commodity at a specific price. An
                                  option on a commodity futures contract gives the buyer of the option the right to convert the
                                  option into a futures contract. Futures and options must be executed on the floor of a
                                  commodity exchange—with very limited exceptions--and through persons and firms who are
                                  registered with the CFTC. To ensure the financial and market integrity of the nation's futures
                                  markets, the CFTC reviews the terms and conditions of proposed futures and option contracts.
                                  The Commission conducts daily market surveillance and can, in an emergency, order an
                                  exchange to take specific action or to restore orderliness in any futures contract that is being
                                  traded. The CFTC also seeks to protect customers by requiring registrants to disclose market
                                  risks and past performance information to prospective customers, by requiring that customer
                                  funds be kept in accounts separate from those maintained by the firm for its own use, and by
                                  requiring customer accounts to be adjusted to reflect the current market value at the close of
                                  trading each day. In addition, the CFTC monitors registrant supervision systems, internal
                                  controls and sales practice compliance programs.
                    SEC           The Division of Market Regulation regulates the major securities market participants: broker-
                                  dealer firms; self-regulatory organizations (SROs), which include the stock exchanges and the
                                  National Association of Securities Dealers (NASD), Municipal Securities Rulemaking Board
                                  (MSRB), and clearing agencies (SROs that help facilitate trade settlement); transfer agents
                                  (parties that maintain records of stock and bond owners); and securities information
                                  processors. (A self-regulatory organization is a member organization that creates and enforces
                                  rules for its members based on the federal securities laws. SROs, which are overseen by the
                                  SEC, are the front line in regulating broker-dealers.) The Division also oversees the Securities
                                  Investor Protection Corporation (SIPC), which is a private, non-profit corporation that insures
                                  the securities and cash in the customer accounts of member brokerage firms against the failure
                                  of those firms. The Division of Corporation Finance oversees corporate disclosure of important
                                  information to the investing public. The Division of Corporation Finance reviews documents that
                                  publicly-held companies are required to file with the Commission. The Division of Investment
                                  Management oversees and regulates the $15 trillion investment management industry and
                                  administers the securities laws affecting investment companies (including mutual funds) and
                                  investment advisors.




                                                       33
October 10, 2002                        MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                                   ENTITIES/ACTIVITIES AGENCIES REGULATE
                     AGENCY                                        ENTITIES/ACTIVITIES AGENCY REGULATES
                      NASD               NASD oversees the activities of over 5,400 securities firms and their more than 91,000 branch
                                         offices, and in excess of 678,000 registered securities professionals. It also regulates the
                                         markets operated by The Nasdaq Stock Market, Inc. NASD carries out its regulatory
                                         responsibilities through education, registration, and testing of securities professionals; onsite
                                         examinations of securities firms to determine their compliance with federal securities laws, the
                                         rules of the Municipal Securities Rulemaking Board, and NASD rules and regulations;
                                         continuous automated surveillance of the markets operated by The Nasdaq Stock Market, Inc.;
                                         review of advertising and sales literature as well as underwriting arrangements proposed by
                                         securities firms in connection with new securities offerings; and cooperative programs with
                                         governmental agencies and industry organizations to solve problems affecting investors, public
                                         companies, and securities firms. For firms that are solely members of NASD and no other self-
                                         regulatory organization, NASD is the exclusive examining authority. If a firm belongs to
                                         multiple self-regulatory organizations, the SEC designates one as the principal examining
                                         authority for determining the firm's compliance with the financial responsibility requirements
                                         under federal securities laws. NASD is the designated examining authority for many members
                                         that maintain affiliations with other self-regulatory organizations.
                                         STATE SECURITIES REGULATORS
                   IL Securities         Registers securities offerings and the persons who sell them. Regulates salespersons/agents;
                                         investment advisors; investment advisor representatives; business brokers; mutual funds; loan
                                         brokers; business opportunities; and unit investment trusts (a specialized investment company
                                         that purchases a fixed portfolio of stocks, bonds, or other securities. Investors purchase units
                                         of the trust, which represent an undivided ownership in the entire portfolio.)
                   IN Securities         Registered mortgage loan brokers; investment advisors; investment advisor representatives;
                                         franchises; collection agencies; and continuing care facilities.
                   IA Securities         Regulates and investigates the sale of securities within the State of Iowa and provides for the
                                         licensing of securities sales agents and dealers. Also administers and enforces the
                                         Prearranged Funeral Contracts Act, the Business Opportunity Promotions Act, the Residential
                                         Service Contracts Act, the Motor Vehicle Service Contracts Act, the Continuing Care
                                         Retirement Community Act; and the Sales of Cemetery Merchandise Act to ensure conformity
                                         and protection of the public.
             MI OFIS Securities          Register and exempt securities offerings; register investment advisers; securities
                                         broker/dealers, finders, agents; inspect and examine investment advisers and broker/dealers;
                                         provide investor education materials; debt management firms; and living care facilities.




                                                              34
October 10, 2002                        MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP

                                   ENTITIES/ACTIVITIES AGENCIES REGULATE
                     AGENCY                                      ENTITIES/ACTIVITIES AGENCY REGULATES
                   WI Securities         Licensed securities sales agents; investment advisor representatives; and licensed
                                         broker/dealers. Also permits the offering of franchise opportunities; registration or exemption of
                                         corporate-type securities; and mutual funds.
                                         STATE INSURANCE REGULATORS
                   IL Insurance          Insurance or surety companies, including a corporation, company, partnership, association,
                                         society, order, individual or aggregation of individuals engaging in or proposing or attempting
                                         to engage in any kind of insurance or surety business, including the exchanging of reciprocal
                                         or inter-insurance contracts between individuals, partnerships and corporations.
                   IN Insurance          Organization, supervision, regulation, examination, rehabilitation, liquidation, and/or
                                         conservation of all insurance companies. Regulates all persons, firms, partnerships,
                                         corporations, associations, orders, societies, and systems and associations operating as
                                         Lloyds, interinsurers, or individual underwriters to make insurance under Indiana law which are
                                         doing or attempting to do, or which are representing that they are doing an insurance business
                                         in Indiana, or which are in process of organization for the purpose of doing or attempting to do
                                         such business. All domestic, foreign, and alien companies authorized to do business in
                                         Indiana.
                   IA Insurance          Supervises all insurance business transacted in Iowa, including health maintenance
                                         organizations and mutual hospital and health service corporations. Grants permission to
                                         companies wishing to sell insurance in Iowa and has general control over all aspects of their
                                         business, from the forms they use to the rates they charge.
             MI OFIS Insurance           Producers, insurers, premium finance companies, Blue Cross Blue Shield of Michigan; HMOs;
                                         Medicare HMOs; no fault certification; personal automobile insurers; pre-licensing schools;
                                         surety companies; surplus lines insurers; third party administrators; workers’ compensation
                                         insurers, limited liability pools, fraternal benefit societies, nonprofit health care corporations, risk
                                         retention groups, and nonprofit dental care corporations.
                   WI Insurance          Agents; insurers and mutual insurers licensed to do business in Wisconsin; fraternal societies;
                                         health care plans; motor club services; risk sharing plans; school benefit plans; service
                                         corporations; surety companies; town mutuals; workers’ compensation; risk retention groups;
                                         and risk purchasing groups.




                                                               35
October 10, 2002                MIDWEST INTERAGENCY EMERGING ISSUES TASK FORCE GROUP



                                     ON-LINE GLOSSARIES

                   INDUSTRY                                                  ON-LINE GLOSSARY
                    Banking                            http://www.americanbanker.com/glossary.html
                                                       http://www.chicagofed.org/publications/glossary/index.cfm
                   Securities                          http://www.investorwords.com/
                                                       http://www.nasd.com/glossary/a.asp
                                                       http://www.cftc.gov/opa/brochures/opaglossary.htm
                   Insurance                           http://www.naic.org/help/html/gloss.htm
                                                       http://www.insweb.com/learningcenter/glossary/
                                                       http://www.ucalgary.ca/MG/inrm/glossary/
                                                       http://www.lcgroup.com/explanations/




                                                  36

				
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