On April 15, 2016, the IRS released a generic legal advice memorandum (GLAM 2016-001) (the “April GLAM”) addressing the impact of so-called “bad boy” guarantees (also known as nonrecourse carve-out guarantees) on the characterization of underlying partnership debt as recourse vs. nonrecourse under Section 752 of the Internal Revenue Code.
Last week, the Federal Trade Commission announcedamendments to the Telemarketing Sales Rule (TSR) relating to the telemarketing of debt relief services, including new restrictions on advance fees charged by debt relief companies.
Today, the Board of the Federal Deposit Insurance Corporation took the following actions:
Yesterday, the Office of the Commissioner of Financial Institutions of the Commonwealth of Puerto Rico closed Westernbank Puerto Rico, headquartered in Mayaguez, Puerto Rico, and the FDIC was appointed receiver.
Yesterday, the Office of the Commissioner of Financial Institutions of the Commonwealth of Puerto Rico closed R-G Premier Bank of Puerto Rico, headquartered in Hato Rey, Puerto Rico, and the FDIC was appointed receiver.
Yesterday, the Washington Department of Financial Institutions closed Frontier Bank, headquartered in Everett, Washington, and appointed the FDIC receiver.
Yesterday, the Office of the Commissioner of Financial Institutions of the Commonwealth of Puerto Rico closed Eurobank, headquartered in San Juan, Puerto Rico, and the FDIC was appointed receiver.
Yesterday, the Office of the Comptroller of the Currency closed BC National Banks, headquartered in Butler, Missouri, and appointed the FDIC receiver.
Yesterday, the Department of Insurance, Financial Institutions & Professional Regulation of the Missouri Division of Finance closed Champion Bank, headquartered in Creve Coeur, Missouri, and appointed the FDIC receiver.
Yesterday, the Michigan Office of Financial and Insurance Regulation closed CF Bancorp, headquartered in Port Huron, Michigan, and the FDIC was appointed receiver. As receiver, the FDIC entered into a purchase and assumption agreement with First Michigan Bank, headquartered in Troy, Michigan, to assume all of the deposits of CF Bancorp.