TCF Bank 2015 Annual Report Download - page 121

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106
On October 29, 2015, TCF received a Notice and Opportunity to Respond and Advise letter ("NORA Letter") from the
CFPB notifying TCF that the CFPB’s Office of Enforcement is considering recommending that the CFPB take legal
action against TCF related to compliance with laws relating to unfair, deceptive and abusive acts and practices and
Regulation E, §1005.17, in connection with TCF’s practices in administering checking account overdraft program "opt-
in" requirements. The purpose of a NORA Letter is to ensure that potential subjects of enforcement actions have the
opportunity to present their positions to the CFPB before an enforcement action is recommended or commenced and
TCF has provided the CFPB with a written statement setting forth the reasons of law and policy why it believes that
the CFPB should not take action. TCF is in discussions with the CFPB and is seeking to reach an appropriate resolution
of the matter. We are currently unable to predict the ultimate timing or outcome of this matter. There can be no assurance
that the CFPB will not utilize its enforcement authority through settlement, administrative proceedings or litigation and
seek remediation, disgorgement, penalties, other monetary relief, injunctive relief or changes to TCF’s business
practices or operations, which could have a material adverse effect on TCF.
Note 25. Accumulated Other Comprehensive Income (Loss)
The components of other comprehensive income (loss) and the related tax effects are presented in the table below.
(In thousands) Before Tax Tax Effect Net of Tax
Year Ended December 31, 2015:
Securities available for sale:
Unrealized gains (losses) arising during the period $ (2,523) $ 955 $(1,568)
Reclassification of net (gains) losses to net income 1,159 (407)752
Net unrealized gains (losses) (1,364) 548 (816)
Net investment hedges:
Unrealized gains (losses) arising during the period 7,613 (2,900) 4,713
Foreign currency translation adjustment:(1)
Unrealized gains (losses) arising during the period (8,304) — (8,304)
Recognized postretirement prior service cost:
Reclassification of net (gains) losses to net income (46) 17 (29)
Total other comprehensive income (loss) $ (2,101) $ (2,335) $ (4,436)
Year Ended December 31, 2014:
Securities available for sale:
Unrealized gains (losses) arising during the period $ 29,071 $ (10,932) $ 18,139
Reclassification of net (gains) losses to net income (76) 29 (47)
Net unrealized gains (losses) 28,995 (10,903) 18,092
Net investment hedges:
Unrealized gains (losses) arising during the period 3,126 (1,181) 1,945
Foreign currency translation adjustment:(1)
Unrealized gains (losses) arising during the period (3,704) — (3,704)
Recognized postretirement prior service cost:
Reclassification of net (gains) losses to net income (47) 17 (30)
Total other comprehensive income (loss) $ 28,370 $ (12,067) $ 16,303
Year Ended December 31, 2013:
Securities available for sale:
Unrealized gains (losses) arising during the period $ (61,177) $ 23,053 $ (38,124)
Reclassification of net (gains) losses to net income (860)324 (536)
Net unrealized gains (losses) (62,037) 23,377 (38,660)
Net investment hedges:
Unrealized gains (losses) arising during the period 1,625 (614)1,011
Foreign currency translation adjustment:(1)
Unrealized gains (losses) arising during the period (1,979) — (1,979)
Recognized postretirement prior service cost:
Reclassification of net (gains) losses to net income (46) 18 (28)
Total other comprehensive income (loss) $ (62,437) $ 22,781 $ (39,656)
(1) Foreign investments are deemed to be permanent in nature and therefore TCF does not provide for taxes on foreign currency translation adjustments.