BANKING LAW - scbankers.org Law Presentation.pdf · BANKING LAW V. Nicole (Nici) Comer, Esq. SVP/Corporate Counsel, South State Bank Lindsey C. Livingston, Esq. Adams and Reese LLP

BANKING LAW

V. Nicole (Nici) Comer, Esq. SVP/Corporate Counsel, South State Bank

Lindsey C. Livingston, Esq. Adams and Reese LLP

Overview

Forums As to Disputes

Lending – Commercial & Consumer

Consumer Issues

Banking Operations

Bankruptcy Overview

Jurisdiction/Forums As to Disputes

Magistrates Courts – Local Counties – up to

$7,500.00

Circuit Court – Criminal and Civil

Master in Equity – Foreclosures

Special Referee

Federal Court

Diversity of Parties (Citizenship/principal place of

business)

Amount in controversy exceeds $75,000

Bankruptcy Courts – Chapters 7, 9, 11, 12 & 13

Lending – Commercial and Consumer

Rights of parties – statutes, contracts or

case law

Articles 3, 4, and 9 – Uniform

Commercial Code (UCC)

Article 3: deals with negotiable instruments

(checks)

Article 4: banking transactions

Article 9: secured transactions


(cont.)

Contracts

Note – Contract

Checking Accounts – Signature Card

Merchant Accounts – Merchant Agreement

Remote Deposit Agreement

Online Banking

ACH Agreement


(cont.)

Unsecured/Secured

Note

Security Agreement (UCC)

What constitutes a “security interest”?

Written security agreement signed by debtor

(exceptions) describing the collateral,

Value given, and

Debtor has right in the collateral.


(cont.)

Security Agreement (cont.) What is perfection? – Purpose is to give notice to the

work of a potential security interest; prior competing claims.

Adverse Claimants Other security interests

Levy on a judgment

Purchasers

Debtor in bankruptcy – Trustee

Methods Possession/Control

Actual

Control Agreements


(cont.)

Security Agreement (cont.)

What is perfection? (cont.)

Titles – Vehicles, mobile homes, boats

Filing financial statements (UCC)

County where collateral located – fixtures and as extracted collateral or timber to be cut.

Location of Debtor – Everything else – furniture, fixtures, equipment, accounts receivables, etc.

Definition – Location of Debtor

State of formation for entities that must register to come into exists – corporations, LLC, LLP, LP, etc. (SC Secretary of State, www.scsos.com)

Other entities – Place of chief executive office

Foreign Debtor – Washington, D.C.

Individual – Principal residence


(cont.)

Key Points to Remember UCC Statement is not a substitute for a

security agreement

Good for 5 years – Must be continued in last 6

months.

Relates back – do not lend on verbal

representation that debt has been paid – have

prior filing terminated.

File UCC within 10 days or lose in bankruptcy

UCC Financing Statement Example


(cont.)

Recovery – Liquidation

Voluntary Surrender

Peaceful repossession allowed in S.C. – must be without breach of peace

Claim and delivery

Commercially reasonable sale

Private/public sale

Receivership

Maintain

Taxes and Insurance

Collect Income


(cont.)

Mortgage Real estate closings – Unauthorized Practice of Law –

Wachovia v. Coffey

Recording procedure – County where property located

Title priority – Opinion letter, insurance

How is a title insurance claim processed?

Mortgage loan modification

Foreclosure – Judicial sale state

Appraisal rights

Owner occupied foreclosures

Deeds-in-lieu of foreclosure

1099 – Debt Forgiveness (Loan Balance – Appraised Value)

Mortgage Fraud – At Closing – Appraisals, deposits, flipping, etc.

Foreclosure Process in SC

1) Title Exam. A title exam must be performed to determine what parties may have mortgages, liens or other claims on the property. These other parties are then named as defendants in the foreclosure action.

2) Lis Pendens. The party foreclosing on a mortgage lien must file a lis pendens. The lis pendens gives constructive notice of the foreclosure action to any subsequent purchasers or creditors. A lis pendens must be filed no more than 20 days before the filing of the complaint and no less than 20 days prior to the entry of a foreclosure decree. If filed more than 20 days before the filing of the complaint, the lis pendens is automatically invalid. Service of the lis pendens must be made within 60 days after the date of its filing or it will be rendered invalid.

3) Summons and Complaint. A Summons and Complaint is filed detailing the legal grounds under which the Lender is entitled to foreclose its mortgage lien against the real property. Once filed, the Summons and Complaint is served on all defendants. Once served, the defendants have 30 days to respond to the Summons and Complaint. Responses to the Complaint may contest the amount due to Lender or the priority of its lien. Responses may also assert affirmative claims against the Lender.


4) Receiver. In some foreclosure actions it may be prudent to seek appointment of a receiver to collect rents, etc., from the property during the pendency of the action. Once appointed, the Receiver files monthly reports with the Court detailing its activities during the preceding month, particularly the income received and the expenses paid, as well as any repairs or other significant events during the month. The Receiver's appointment runs through the conclusion of the Foreclosure Action, and it is relieved of its duties following the issuance of a deed from the Court. During the Foreclosure Action, the Receiver is responsible for handling the real property, while the court is responsible for managing the foreclosure process and determining the rights of the parties.

5) Reference. Following the receipt of any responses to the Complaint, the Foreclosure Action is referred to the Master in Equity, a division of the Circuit Court specifically designated to hear real estate mortgage lien foreclosures. Generally, a reference is made upon consent by all parties not in default. However, should a party not consent to the reference, a motion for mandatory reference is proper in that a mortgage foreclosure action is equitable in nature.


6) Foreclosure Hearing. All defendants are given notice of the scheduled foreclosure hearing. At the hearing, the Master in Equity determines lien priorities and orders the foreclosure sale of the real property on a day certain.

7) Deficiency Judgment. In order to request a deficiency judgment against the borrower, the Lender specifically requests it in the Summons and Complaint and other pleadings filed with the court.

If a deficiency is waived, the foreclosure order will not be a personal

judgment against the borrower.

Absent such a waiver, the decree of foreclosure establishes a personal judgment against the borrower. There are two ways this personal judgment may be entered. First, the court may enter a personal judgment for the total debt after the hearing. The net proceeds of the sale are then applied to reduce the balance due on the judgment debt. Alternatively, the court can order that a deficiency judgment be granted after the sale. After the sale, the court determines the amount of the deficiency and enters a personal judgment for that amount. Under either procedure, the borrower or other proper defendants may demand that the property be appraised to determine if the high bid at sale was a fair price for the property.


8) Notice and Sale of the Property. Prior to the property being sold at a public foreclosure sale, a Notice of Sale must be advertised once a week for three weeks prior to the sale date in the local newspaper of general circulation.

Bidding: Lender determines the amount that it will bid at the foreclosure sale, typically either the lower of the amount of the indebtedness owed to it or the value of the real property. At the foreclosure sale, if the Lender waives its deficiency claim, the Lender may bid more than once at the sale and the sale is concluded that day with the property being sold to the highest bidder. If the Lender has specifically requested a deficiency, then the Lender may only bid once at the sale, and the bidding must remain open for a period of 30 days to allow for additional bids. In either case, a successful bidder must place a 5% deposit and has 20 days to comply with their bid. The Lender may credit bid at the sale.

9) Deed. Once the high bidder has complied with his or her bid, the Master in Equity executes a deed to the purchaser. Thereafter, title to the real property vests in the winning bidder and the Receiver is discharged of their duties.

The entire foreclosure process typically runs 120-260 days depending on a variety of factors, including: the number of parties to be served with the Summons and Complaint; issues with obtaining proper service of the Summons and Complaint on defendants; the responses received to the Complaint; the number of responses filed to the Summons and Complaint; and the Court's availability for scheduling hearings.


Workouts Forbearance, Modification and Extension Agreements

– Who Signs? Everybody with an interest in the transaction.

Lender Liability Breach of Contract

Fraud

Misrepresentation

Breach of Fiduciary Duty

Breach of Duty of Good Faith and Fair Dealing

Negligence

Unclean Hands

Unfair Trade Practice

Equitable Estoppel


(cont.)

Participation Loans – Issues

Rights of Participants

Lead Bank

Participating Bank

Allocation of Expense/Income

Decision Making – Lead Bank – with

exception

Completion of Foreclosure – ongoing

administration


(cont.)

You get a Judgment, now what? – Process for

Collecting!

Supplemental Proceeding

Garnishment of wages – Not available in South

Carolina

Receivers

Other counties/states

Counties – administrative transfer

States – file lawsuit to domesticate/file

Judgment rate of interest

Lending – Commercial and

Consumer (cont.)

Statute of Elizabeth – transfers

Intent to delay, hinder or defraud creditors;

Rebuttable presumption of fraud;

Where the transfer was not made on valuable consideration, no actual intent to hinder or delay creditors must be proven.

Instead, as a matter of equity, the transfer will be set aside if the plaintiff shows that (1) the grantor was indebted to him at the time of the transfer; (2) the conveyance was voluntary; and (3) the grantor failed to retain sufficient property to pay the indebtedness to the plaintiff in full – not merely at the time of the transfer, but in the final analysis when the creditor seeks to collect his debt.

Consumer Issues

Consumer Loan – Made by a person regularly engaged in the business of making loans in which: Debtor is a person other than an organization;

Debt is incurred primarily for personal, family, or household purposes;

Entire debt is payable in installments or a loan finance charge is made; and

Either the principal does not exceed $87,500 or the debt is secured by an interest in land. (1st mortgage loan excluded)

**The “purpose” of the loan determines if it is a consumer Loan – not the type of collateral.**

Lending –Consumer Protection Statutes

S.C. High Cost Home Loan Act

Targets practices commonly referred to as

predatory lending.

Requires lenders of high cost home loans to receive

written certification that a borrower has received

counseling from a HUD or South Carolina Housing

Finance Agency on “the advisability of the loan

transaction.”


South Carolina Consumer Protection Code (SCCPC)

Provides comprehensive regulation of many types of credit.

Applies to everything from consumer credit sales, insurance, and consumer leases to consumer rental purchase agreements.

Sets forth statutory remedies and civil penalties.

Does not apply to first mortgage on borrower’s residence


Dodd-Frank Wall Street Reform and Consumer

Protection Act (“Dodd-Frank Act”)

Massive and complex new law- aimed at addressing

systemic risks, corp. governance, hedge

funds/derivatives, proprietary trading as well as

consumer reform

Created the Consumer Financial Protection Bureau

(“CFPB”)- authority to regulate consumer financial

services and providers


Regulation Z – Truth-in-Lending Act (TILA)

Federal law requiring standardized disclosures to promote informed use of consumer credit.

It gives consumers the right to cancel certain credit transactions that involve a lien on a consumer's principal dwelling, regulates certain credit card practices, and provides a means for fair and timely resolution of credit billing disputes.


TILA Revised by Dodd-Frank

Qualified Mortgages New class of mortgages viewed as sufficiently safe to allow safe

harbor from restrictions/prohibitions imposed by the Act

Rebuttable presumption that the borrower has ability to repay

Key Features of QMs:

No excessive upfront fees/points

Borrower’s information for qualifying for loan is verified/documented

No toxic loan features- i.e. no interest only loans, negative

amortization loans, no balloons

Limits Debt-to-Income Ratios


TILA Revised by Dodd-Frank- General Rules/Prohibitions

Lender must ensure borrowers can repay loan over full term

Prepayment penalties banned for all adjustable rate and higher cost mortgages that are not QMs

Lender must disclose maximum payment and negative amortization

Residential mortgage loan cannot include financing of any credit insurance


REGULATION AA (UDAP)

Section 5(c) of the Federal Trade Commission Act, as amended

(the “FTC Act”), prohibits a bank from engaging in unfair or

deceptive acts or practices (“UDAP”).

Prohibits Banks from including the following remedies in its

consumer credit obligations:

Confessions of Judgment at time of extension of credit

Waiver of Borrower’s opportunity to be heard in a lawsuit

Waiver of property exemptions provided under state law

Assignment of future wages

Security interest in household goods other than a purchase money

security interest (certain exceptions- art, antiques, jewelry (other than

wedding bands))


REGULATION AA- Cosigner Rule

“Cosigner” includes any person who assumes liability for a

consumer obligation without receiving goods, services, or money

in return.

Also includes any person whose signature is required as a condition to

(i) granting credit, or (ii) forestalling collection efforts on a consumer's

obligation that is in default.

Does not matter how the person is designated on credit application

Prohibits the Bank from misrepresenting a cosigner’s liability

Bank required to provide a Disclosure Notice to cosigner, prior to

becoming obligated in the consumer credit transaction,

explaining the nature of cosigner’s obligation.


REGULATION AA- Pyramiding Late Charges

Prohibits “pyramiding late charges” which is the imposition of a

late charge resulting from failure to pay an earlier charge.

Example: consumer makes the January payment 15 days late,

but makes the February payment on time and in full.

Bank may not cause the February payment to be considered delinquent

by deducting the late charge applicable to the January payment;

Rule does not prohibit late charges being assessed for every period that

a payment remains not fully paid


Section 1301 of Dodd-Frank Act

Take Regulation AA one step further by prohibiting a

bank from engaging in unfair, deceptive, or abusive acts

or practices (UDAAP).

UDAAP applies to any transaction with a consumer for a

consumer financial product or service, or the offering of

a consumer financial product or service (i.e. over draft

programs, ATM fees, credit card programs, ATM fees,

etc.)

CFPB enforces and can impose penalties and require

refunds


UDAAP What is “unfair’?

practice hinders a consumer’s decision making

Material information withheld so consumer cannot make an informed choice

What is “deceptive”?

practice misleads or is likely to mislead.

“reasonable” consumer would be misled.

presentation, omission or practice is material.

What is “abusive”?

practice materially interferes with the consumers ability to understand a term or

condition of a product or service.

practice takes unreasonable advantage of a consumer’s lack of understanding of

the risk, costs and conditions of a products or service


Regulation B – Equal Credit Opportunity Act

Federal law that makes it unlawful for a lender to

discriminate on the basis of race, color religion,

national origin, sex, marital status, or age among

other things.

Applies with respect to any credit transaction.

Violation can result in civil liability.


Fair Credit Reporting Act

Federal law regulating collection, dissemination, and

use of consumer credit information.

Enforced by the FTC.

Grants consumer rights to review/correct their credit

reports.

Violations can result in civil liability.


Fair Debt Collection Practices Act

Designed to stop abusive practices in the collection of

consumer debts.

Creates guidelines under which debt collectors may operate

and sets forth penalties for violations of the act.’

FDCPA generally applies only to third party debt collectors—

not internal collectors for an "original creditor"

Restricted to personal, family, or household transactions.


Mortgage Lending Act and Mortgage Broker

Licensing Act

Requires the registration and licensing of all

mortgage loan originators and brokers.

Mortgage loans includes manufactured housing.

Companies must be covered by a surety bond

determined using loan volume.

Once licensed, companies must file a report of each

loan application taken in SC.

Other Consumer Issues

Unconscionable Conduct – “Shocks the

Conscience”

Attorney Preference – Debtors right to

chose closing attorney – timing

Specific Notice Requirements –

Cosigner & Cure


Allowable Fees

Fee Authorization – Section 37-3-202

Lenders may charge certain specified fees in

addition to loan finance charges, including

charges for insurance, official fees and taxes,

and fees paid to registered mortgage loan

brokers

Adjustment Dollar Amount

SC Department of Consumer Affairs

Website – www.consumer.sc.gov


Disclosures – Use only Consumer Note

Forms

Mortgage Satisfaction Requirements –

within 90 days of payment in full –

request to satisfy

Penalty up to $25,000

Operations

Check Processing/Accounts

2008 Significant Changes

Article 3 & 4:

Variation by Agreement

Notice to Customer

Accord & Satisfaction

Post dated checks

Daily cutoff time – 2 p.m.

Time to review statements – 30 days

Operations (cont.)

Check Processing/Accounts (cont.)

Endorsements

Blank – Sign name only

Special – Pay to the order of . . .

Restricted – For Deposit Only

Maker liability/forgeries – Maker’s bank usually suffers loss

Endorser liability/forgeries – Person who has best opportunity to verify signature usually takes the loss

Representation and warranties – All signatures valid

Operations (cont.)

Check Processing/Accounts (cont.)

Stop Payments – How much time do you

have to process?

Whatever is reasonable – Is this one minute?

Bank responsibility to customers of joint

accounts

Customers Responsibilities

Operations (cont.)

EFT Fraud

For example, SC Dep’t of Consumer Affairs

previously issued a scam alert for student loan

repayment.

The scammers claimed to “have the secret to

erase student loan debt” based on the U.S.

Constitution.

Scammers told consumers to write “EFT

ONLY” on the check.

Operations (cont.)

Power of Attorney – Section 62-5-501 et

seq.

Durable

Recorded

Executed Property

Terminates Upon Death

Required to Accept?

Operations (cont.)

Subpoenas

Often arise in domestic disputes

Copies – redaction!

Removing Party from Account

Operations (cont.)

Identity Theft –

Upon determination, immediate action

should be taken

Consumers generally not liable on checks

they did not sign.

Banks have some statutory liability via the

Electronic Fund Transfer Act and Fair

Credit Billing Act.

Operations (cont.)

Right to Offset – What is it?

Contract

Statute – Section 62-6-113

Courts – Criteria:

Mutuality of Identify (joint accounts?);

Each debt due; and

Reasonable Notice

Offset Prohibited – In connection with

Credit card debt;

IRA account; and

Social Security funds

Operations (cont.)

Miscellaneous

Safe Deposit Boxes – Section 34-19-10 et seq.

Lease to minor – Yes

Access to box of decedent – Spouse, parent, child or

named PR – original Will, burial plot certificate, or

insurance policy.

Co-renters – rights

Failure to pay rent

1 year default – 30 day notice registered mail –

drill/inventory/notary – send inventory list – seal- store

for 2 years

Operations (cont.)

Miscellaneous (cont.)

Banking with Minors – Section 34-11-20

“A bank may accept deposits of and pay out

deposits upon a check or other order of a minor

and act in any other matter with respect to the

deposits of a minor with the same effect as if

dealing with a person of full legal capacity.”

Operations (cont.)


Duplicate for Lost or Destroyed Certificates

of Deposits – Section 34-11-40 & 34-11-50

Holder of the certificate shall make affidavit

that the certificate has been lost and not

transferred, assigned, etc.

Depository can require the holder to execute

a bond to indemnify the depository for any

losses caused by the original certificate within

3 years.

Operations (cont.)


Adverse Claimants of Deposits – Section 34-11-

110

Adverse claimants must procure a restraining order,

injunction, or other appropriate process where the

person to whose credit the deposit stands is made a

party; or

The claimant must execute a bond indemnifying the

bank from all liability resulting from the payment of

the adverse claim.

Operations (cont.)


Types of Accounts – Section 62-6-101

Single

Joint

Multi-Party

P.O.D.

Trust

Vary By Agreement

Operations (cont.)


Unclaimed Property Act – Section 27-18-10 et seq

Intangible property including income is presumed abandoned if unclaimed for more than 5 years.

Once determined abandoned, property is subject to the custody of the State of South Carolina if certain conditions are met such as if the last known address of the apparent owner is in South Carolina or the holder does not know the identity of the person entitled to the property and it is established that the last known address of the person entitled to the property is in South Carolina.

Bankruptcy

Chapters

Chapter 7 – Personal – Liquidation

Chapter 9 – Municipalities

Chapter 11 – Business – Reorganization

(occasionally used by consumers)

Chapter 12- Family Farmers

Chapter 13 – Consumer – Wage Earner

Chapter 15- Cross Border Insolvency

Chapter 7

Always used for liquidation

Available to anyone (individuals, corporations, partnerships, limited liability companies, farmers, fishermen)

Chapter 7 trustee appointed who takes control over all assets of the debtor

Trustee reviews the case carefully to see if there are any assets that can be found that can be liquidated and used:

To pay the trustee’s commission

To pay creditors

“Assets” include:

Tangible things (land, jewelry, watches, cars)

“Intangible things” (lawsuits, claims, insurance policies)

Chapter 11

Who can file: “Rich” individuals

Current trend, at least in South Carolina, is real estate owners/developers

Corporations

Why file/purposes: Reorganization

To receive protection from creditors who are seeking to collect and/or to change the terms of repayment of debts to those creditors (restructuring of the balance sheet)

The creditors that push a debtor into bankruptcy can be the obvious (banks) or the not so obvious (legacy debt, i.e. retiree claims)

Theoretically, a debtor could completely change the nature of its business but continue as a going concern

Partial reorganization To liquidate part of the debtor’s assets, pay off some creditors, reduce debt,

and continue as a going concern with what remains

Chapter 11

Partial Reorganization and Reorganization can also result in new ownership of the reorganized debtor, as existing shareholders are wiped out, and new shares in NEWCO are issued to creditors

Liquidation

Liquidate the assets, wind up the operations of the business

Chapter 11

All of the foregoing are generally

accomplished through a Chapter 11 plan

and disclosure statement:

Disclosure Statement: the Debtors’

autobiography

Who we were;

What went wrong;

How we’re gonna fix it.

The Plan: how we’re gonna fix it.

Chapter 13

Provides for adjustment of debts of an individual with

regular income.

Chapter 13 allows a debtor to keep property and pay

debts over time, usually three to five years.

Individual files a repayment plan for payment of their

debts.

Generally, a chapter 13 debtor is entitled to a discharge

upon completion of all payments under the chapter 13

plan.

Chapter 9

Governs reorganization of municipalities (which includes

cities and towns, as well as villages, counties, taxing

districts, municipal utilities, and school districts)

Must meet certain eligibility requirements

Court has limited power in Chapter 9 cases- cannot

interfere with the operations of the debtor or with the

debtor's use of its property and revenues.

Chapter 9 cases are rare, however, are being used more

frequently

Chapter 12

provides for adjustment of debts of a "family farmer," or a

"family fisherman" with regular annual income

Chapter 12 eliminates many of the barriers such debtors

would face if seeking to reorganize under either Chapter

11 or 13 of the Bankruptcy Code.

Chapter 12 is more streamlined, less complicated, and

less expensive than chapter 11

Chapter 15

Chapter added in 2005 to the Bankruptcy Code entitled

“Ancillary and Other Cross Border Cases.”

Governs cross-border insolvency

The purpose of Chapter 15 is to provide effective

mechanisms for dealing with insolvency cases involving

debtors, assets, claimants, and other parties of interest

involving more than one country.

Voluntary v. Involuntary

Voluntary:

i. “We’re in trouble, and we just cant take it anymore” or

ii. “We’re in trouble, our bank wants us to file”

Examples- Circuit City, Bi-lo

Involuntary: “We’re pretending that we’re fine, but our creditors don’t think so, and 3 or more of them with undisputed debts totaling $14,425.00, get together and put us in bankruptcy themselves.”

Bankruptcy

Notice of Filing

Date of filing and case number – important

Identification of Debtor, Debtor’s attorney and Trustee

Date of first meeting of Creditors

Whether the claim should be filed

Borrower/Deadline Dates

First Meeting of Creditors

Automatic Stay

The Automatic Stay

The automatic stay stops everything having to do with the collection of a debt.

Automatically in place upon filing of bankruptcy petition

Very broad; stays ALL collection actions and ALL actions to enforce security interests against the debtor

Thus, after a bankruptcy is filed, you cannot communicate with the debtor related to the collection of pre-bankruptcy debt, nor can you commence or continue any collection efforts against the debtor.

If a creditor knows about the debtor’s bankruptcy but continues to attempt to collect anyway, the creditor risks having to pay damages, including attorney’s fees, costs, and maybe even punitive damages.

Duration of the Automatic Stay

The automatic stay remains in effect throughout the bankruptcy case.

The stay with respect to property continues until the property is no longer property of the estate. This means that the stay continues with respect to

the property until the trustee abandons the property or the property is sold, or otherwise disposed of.

The stay of any other act continues until the earliest of: The time the case is closed.

The time the case is dismissed.

If applicable, the time a discharge is granted or denied.

Notice of Bankruptcy

When a bankruptcy case is filed, the bankruptcy court mails a notice to each scheduled creditors informing it of the case filing and other pertinent information.

The notice also will state whether a claim should be filed or not (e.g., if it is a “no asset” case, the notice will instruct you not to file a claim at this time).

If the notice says to file a claim, the notice also will (a) state the date by which the claim must be filed for governmental and non-governmental creditors (the “bar date”), and (b) include a “Proof of Claim“ form as an attachment to the notice.

http://www.scb.uscou

rts.gov/pdf/local_for

ms/poc.pdf

First Meeting of Creditors

341 Meeting- opportunity for creditors to

question the debtor under oath

Can ask anything- typically as about

collateral (i.e. insured, taxes paid, other

liens, intentions, ability to maintain

payments)

Questions?

How to Contact Us

V. Nicole (Nici) Comer:

South State Bank

[email protected]

803 540 2443 (direct)

Lindsey Carlberg Livingston:

Adams and Reese LLP

[email protected]

803 212 4409 (direct)

Documents

BANKING LAW - scbankers.org Law Presentation.pdf · BANKING LAW V. Nicole (Nici) Comer, Esq. SVP/Corporate Counsel, South State Bank Lindsey C. Livingston, Esq. Adams and Reese LLP