If you walk like a bank and talk like a bank, are you really a “bank”? What are Section 3(a)(2) bank note programs, and which issuers are eligible to use them? Why do national banks exempt from registration under the Securities Act still have to follow the OCC’s securities offering disclosure rules? Find the answers in our new What’s the Deal? article on Section 3(a)(2) bank note programs, in the latest of our What’s the Deal? series.