On June 8, in response to the enactment of the Paycheck Protection Program (PPP) Flexibility Act, the Small Business Administration (SBA and the U.S. Treasury jointly announced that the SBA will promptly issue rules and guidance, a modified borrower application form, and a modified loan forgiveness application implementing these legislative amendments to the PPP. These modifications will implement the following important changes: Extend the covered period for loan forgiveness from eight weeks after the date
REVISED CHARM BOOKLET
Category: CFPB, CHARM Booklet, Regulation X, Regulation Z, RESPA, Truth in Lending
On June 9,2020 the Consumer Financial Protection Bureau (CFPB) announced the availability of an updated consumer publication, the Consumer Handbook on Adjustable Rate Mortgages booklet, also known as the CHARM booklet, required under the Real Estate Settlement Procedures Act (RESPA) implemented by Regulation X and the Truth in Lending Act (TILA) implemented by Regulation Z. New features include: A comparison table that describes adjustable rate mortgages and their differences in relation to fixed-rate loan products;
On June 5 the president signed the Paycheck Protection Program Flexibility Act of 2020 (Flexibility Act). The Flexibility Act makes numerous changes, including, but not limited to,: Extends the maturity period for new PPP loans made after June 5, 2020, from two to five years. By mutual agreement of the lender and the borrower the maturity on existing PPP loans may be extended. Payments of principal and interest on existing PPP loans were deferred for
ELECTRONIC CREDIT CARD DISCLOSURES AND COVID-19
Category: CFPB, Coronavirus, E-Banking, Regulation Z, Truth in Lending
On June 3, 2020 the Consumer Financial Protection Bureau (CFPB) issued a Statement on Supervisory and Enforcement Practices Regarding Electronic Credit Card Disclosures in Light of the COVID-19 Pandemic. The Issue Where underlying law, such as Regulation Z, requires a written disclosure to a consumer, the Electronic Signatures in Global and National Commerce Act (E-Sign Act) allows the disclosure to be provided electronically subject to certain conditions, including consumers’ consent–commonly known as “E-Sign consent.” Some
On May 22, 2020 the Small Business Administration (SBA) and the Department of Treasury jointly issued two interim final rules (IFR) related the Paycheck Protection Program (PPP). The first IFR deals with Loan Forgiveness; the second covers Loan Review Procedures and Related Borrower and Lender Responsibilities. Loan Forgiveness – The 26-page IRF on Loan Forgiveness is designed to: Help PPP borrowers prepare and submit loan forgiveness applications as provided for in the CARES Act; Help
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