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On April 17 the Federal Reserve Board published an interim final rule that excludes loans that are guaranteed under the Small Business Administration’s Paycheck Protection Program (PPP) from many of the requirements of Regulation O. The rule is effective upon publication in the Federal Register, which is expected soon. The comment period expires 45 days after publication in the Federal Register. The final rule excludes from all requirements of Regulation O, except for the executive

On April 16, 2020 the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation C to set the thresholds for reporting data about: Closed-end mortgage loans, so that institutions originating fewer than 100 closed-end mortgage loans in either of the two preceding calendar years will not have to report such data effective July 1, 2020. Open-end lines of credit at 200 open-end lines of credit effective January 1, 2022, upon the expiration of

On April 16, 2020 the Federal Financial Institutions Examination Council (FFIEC) announced the availability of FFIEC Federal Disclosure Computational Tools, including the Annual Percentage Rate (APR) Computational Tool and the Annual Percentage Yield (APY) Computational Tool. The FFIEC member agencies collaborated to develop the Federal Disclosure Computational Tools, which will assist financial institutions in their efforts to comply with the consumer protection laws and regulations. The APR Computational Tool is designed to streamline the process

The Small Business Administration’s Paycheck Protection Program, authorized by the CARES Act, became available on April 3 for small businesses and sole proprietorships and on April 10 for independent contractors and self-employed individuals. Lenders participating in the PPP have been overwhelmed by the number of applicants and are working diligently to process the loans expeditiously. One concern for lenders is providing a quick turnaround while still complying with the Bank Secrecy Act requirements. The SBA

On April 9, 2020 Treasury Secretary Mnuchin approved the establishment of a Main Street Business Lending Program and a Municipal Liquidity Facility to support the flow of credit to American workers, businesses, States, counties, and cities impacted by the Coronavirus pandemic. Main Street Business Lending Program Small and medium-sized businesses, through no fault of their own, have faced severe financial strain from widespread closures and liquidity pressures in the financial system. Using funds appropriated under