INTERAGENCY LENDING PRINCIPLES FOR OFFERING RESPONSIBLE SMALL-DOLLAR LOANS
Category: Coronavirus, FDIC, Federal Reserve Board, NCUA, OCC
On May 20, 2020 the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the National Credit Union Administration jointly issued the Interagency Lending Principles for Offering Responsible Small-Dollar Loans. The agencies: Recognize the important role that responsibly offered small-dollar loans can play in helping customers meet their ongoing needs for credit from temporary cash-flow imbalances, unexpected expenses, or income shortfalls, including during periods of economic stress,
News has been leaking all week, now it is official: The Office of the Comptroller of the Currency (OCC) is publishing a final Community Reinvestment Act (CRA) rule today; Comptroller of the Currency Joseph Otting is resigning tomorrow; and The Federal Deposit Insurance Corporation is not joining the final CRA rule at this time. That leaves many unanswered questions, including what happens next to CRA?
SBA PPP LOAN FORGIVENESS
Category: Coronavirus, PPP Loans
The Small Business Administration (SBA) continues its practice of releasing information on the Paycheck Protection Program (PPP) on an as needed basis. The SBA released the Paycheck Protection Program Loan Forgiveness Application on May 15, 2020. The SBA promises regulations and additional guidance for borrowers and for lenders soon.
On May 13 the Consumer Financial Protection Bureau (CFPB) issued pandemic related information including a Statement on Supervisory and Enforcement Practices Regarding Regulation Z, FAQs on Open-End (not Home Secured) Rules Related to COVID-19, and FAQs on Payment and Deposit Rules Related to COVID-19. A summary of the Payment and Deposit Rules FAQs, which includes three main questions, is provided below. FAQ one addresses whether a financial or depository institution can change account terms for
CFPB FAQS FOR OPEN-END CREDIT AND COVID-19
Category: CFPB, Coronavirus, Regulation Z, Truth in Lending
On May 13 the Consumer Financial Protection Bureau (CFPB) published three Frequently Asked Questions (FAQs) regarding open-end (not home-secured) rules related to the COVID-19 pandemic. The FAQs are “compliance aids,” which do not have the weight of the law or the regulations. The first FAQ addresses changes to account terms. The answer indicates that a creditor may change terms on an open-end account, although most significant changes in terms require advance notice. It clarifies that
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