ABA Banking Journal - November 2007 - (Page 63)

Statement of Ownership, Management, and Circulation 1. Title of Publication: ABA Banking Journal 2. Publication Number: 544-030 3. Date of Filing: September 24, 2007 4. Frequency of issue: Monthly 5. Number of issues published annually: 12 6. Annual Subscription price: $40.00 7. Mailing address of known office of publication: Simmons-Boardman Publishing Corporation, 345 Hudson Street, 12th floor, New York, N.Y. 10014 8. Mailing address of the Headquarters of General Business offices of the publisher: Simmons-Boardman Publishing Corporation, 345 Hudson Street, 12th floor, New York, N.Y. 10014 9. Full names and mailing address of publisher, editor, and managing editor: Publisher, Gus Blumberg; Editor, William W. Streeter; Managing Editor, none; Simmons-Boardman Publishing Corporation, 345 Hudson Street, 12th floor, New York, N.Y. 10014 10. Owner: American Bankers Association, 1120 Connecticut Avenue, N.W., Washington, D.C. 20036. (A voluntary membership association of banks incorporated under the District of Columbia non-profit corporation statute; does not issue stock.) 11. Known bondholders, mortgagees, and other security holders owning or holding one percent or more of total amount of bonds, mortgages, or other securities: None 12. Tax Status: Has Not Changed During Preceding 12 Months 13. Title of Publication: ABA Banking Journal 14. Issue Date for Circulation Data Below: September 1, 2007 15. Extent and nature of circulation: Average No. Copies Each No. Copies of Single Issue During Preceding Issue Published Nearest 12 Months to Filing Date A. Total no. of copies (net press run): 34,943 34,520 studied what information consumers want and how consumers best understand the information they are given. Results of these efforts appear in two recent regulatory proposals: revisions to privacy notices and revisions to open-end credit disclosures. The results are encouraging. The information is clear and well organized. Most of the regulatory boilerplate has been dropped, replaced by words that real people use. The proposed open-end credit disclosures are much more user-friendly than the current disclosures. And because they are presented in a logical way, consumers can more easily understand them. It is interesting to note that these proposals for improved regulations are the result of a bottom-up approach, and not from a top-down approach guided solely by the statute. Regulatory combination platters A consumer-oriented overhaul of the regulations can look at more than one statute or regulation at a time. For example, a disclosure does not need to be limited to a single regulation. It could include the disclosures required by related laws such as the Real Estate Settlement Procedures Act and Regulation B. Think how simple it would be to include a statement in the Truth in Lending box that says the servicing of your loan will/will not/may be transferred, a requirement of RESPA. It would also be simple to include a statement that explains the customer’s right, under Regulation B, to a copy of an appraisal. Some of the most difficult disclosures that are or will be required by the FACT Act could also be dealt with in a similar way. Take, for example, that risk-based pricing disclosure that no one can figure out how to implement. Life would be much simpler—and the disclosure would be easier to understand—if the TIL disclosure simply stated whether the creditor used risk-based pricing and encouraged the consumer to ask about it. Compliance in the future When Congress passes a law, Congress is trying to solve a problem. Right now, the problem Congress is struggling with is predatory lending practices that have done serious harm to consumers and, potentially, to the economy. Here is another chance to pile on regulatory burden—or a chance to make the process more effective and less burdensome. Banks can play an important role in the shape that any action takes. The way to make a difference is to think first about the customer. What products does the customer need? What information should the customer have about those products? What is the best way to present information about the products to the customer? Predators didn’t listen to what customers wanted; they pushed products on customers and walked off with the profits. Congress is trying to put a stop to this. What should banks do? Here is an opportunity. In addition to the opportunity to promote banks as the good players in the industry, this is an opportunity to look hard at what is wrong with the information consumers get and to look for ways to correct that. Banks can come out of this as heroes if they put their customers first and find effective ways to inform their customers about the real terms and risks of a loan. And when you find something that works, share it with the regulators. BJ B. Legitimate Paid and/or Requested Distribution (By Mail and Outside the mail): (1) Individual Paid/Requested Mail Subscriptions Stated on PS Form 3541. (Include direct written request from recipient, telemarketing and internet requests from recipient, paid subscriptions including nominal rate subscriptions, advertiser’s proof copies, and exchange copies): 33,060 32,794 (2) Copies Requested by Employers for Distribution to Employees by Name or Position Stated on PS Form 3541 NONE (3) Sales Through Dealers and Carriers, Street Vendors, Counter Sales, and Other Paid or Requested Distribution Outside USPS NONE (4) Requested Copies Distributed by Other Mail Classes Through the USPS (e.g. First-Class Mail): NONE C. Total Paid and/or Requested Circulation (sum of 15b. (1), (2), (3), and (4): 33,060 D. Nonrequested Distribution (By Mail and Outside the mail): (1) Nonrequested Copies Stated on PS Form 3541 (include Sample copies. Requests Over 3 years old, Requests induced by a Premium, Bulk Sales and Requests including Association Requests, Names obtained from Business Directories, Lists, and other sources): 408 424 (2) Nonrequested Copies Distributed Through the USPS by Other Classes of Mail (e.g. First-Class Mail, Nonrequestor Copies mailed in excess of 10% Limit mailed at Standard Mail or Package Services Rates): NONE (3) Nonrequested Copies Distributed Outside the Mail (Include Pickup Stands, Trade Shows, Showrooms and Other Sources): 558 E. Total Nonrequested Distribution (Sum of 15d (1), (2), and (3): F. Total Distribution (Sum of 15c and e): G. Copies not Distributed H. Total (Sum of 15f and g): NONE NONE NONE 32,794 NONE 425 966 849 34,026 917 34,943 33,643 877 34,520 97.48 % I. Percent paid and/or Requested Circulation (15c divided by f times 100): 97.16 % Maureen Cooney, Circulation Director, September 24, 2007 ABA BANKING JOURNAL/NOVEMBER 2007 63

Table of Contents Feed for the Digital Edition of ABA Banking Journal - November 2007

ABA Banking Journal - November 2007 Contents Editor’s Column Briefing: Good News for Mortgages Sleight of Mind N.Y. Hiring Bonanza May Be Bane Snapshot: A Look at Held-For-Investment Loan Growth ABA Resources ABA Chairman’s Position “The Moose Bank” Thrives on Manufactured Housing Loans Finding the Middle Way for Your Bank’s Retirement Program Pass the Aspirin Cover Story: Self-Service Steps Up DIY U.K. Style Marketing to Millennials Getting Real With “Gen Wired” Ethnic Marketing: Disinterested Banking Getting Good at Global Sourcing Case in Point Turn Compliance on It's Head Banker’s Mart To Advertise/Index of Advertisers The Economy

ABA Banking Journal - November 2007

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