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
CFPB STATEMENT ON REGULATION Z BILLING ERRORS – CLARIFICATION OR ADDED CONFUSION
Category: CFPB, Regulation Z, Truth in Lending
On May 13 the Consumer Financial Protection Bureau (CFPB) published a Statement on Supervisory and Enforcement Practices Regarding Regulation Z Billing Error Resolution Timeframes in Light of the COVID-19 Pandemic (the statement). The Truth in Lending Act generally requires that creditors investigate and resolve consumers’ billing error notices within specified maximum timeframes. Good news – The statement provides notice to creditors that the CFPB intends to take a flexible supervisory and enforcement approach with respect
FLOOD INSURANCE COMPLIANCE IN RESPONSE TO THE CORONAVIRUS
Category: Coronavirus, Federal Reserve Board, Flood Insurance
On May 6, 2020 the Federal Reserve Board issued Consumer Affairs letter CA 20-7 on the topic of Flood Insurance Compliance in Response to the Coronavirus. On March 9, the Federal Reserve Board and the other federal financial institution regulatory agencies and state bank regulators issued a statement to encourage financial institutions to meet the financial services needs of their customers and members in areas affected by the coronavirus.Since that time, the Federal Reserve Board
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