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On January 12, 2010, the Federal Reserve Board approved a final rule (the “Final Rule”) amending Regulation Z (which implements the Truth in Lending Act (TILA)) and the related staff commentary (“Official Staff Interpretations”), in order to implement certain provisions of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (the “Credit CARD Act” or the “Act”) that take effect on February 22, 2010
The repurchase of senior preferred stock sold to the U.S. Treasury Department under the Capital Purchase Program (CPP) is coming to the forefront as a critical and possibly unavoidable decision for every banking organization that has participated in the CPP
