ACME Bank is a state nonmember bank with all of its offices in one state. However, it also has an Internet Web site where it advertises consumer credit and accepts applications from a five-state regional are A. Two of the states are community property states. The other three are not. What is the best explanation for what ACME bank’s management should do to comply with the FDIC ECOA spousal signature guidance?
A. Because ACME has all of its offices within one state, it only has to be knowledgeable of the legal requirements of that state regarding spousal property rights and can apply those laws to all of its operations.
B. ACME must become familiar with the laws of each of the five states and ask for spouse signatures only when appropriate under the law.
C. ACME can choose any of the state laws where it operates to apply to its consumer lending operations.
D. ACME should make only business-purpose loans to avoid the spousal signature rules.
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