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On August 3 the Federal Financial Institutions Examination Council (FFIEC) issued a statement setting forth prudent risk management and consumer protection principles for financial institutions to consider while working with borrowers as initial coronavirus-related loan accommodation periods come to an end and they consider additional accommodations. The COVID event has had a significant adverse impact on consumers, businesses, financial institutions, and the economy. To address some of these impacts, the Coronavirus Aid, Relief, and Economic Security […]

On June 12 the Small Business Administration published an interim final rule (IFR) to update its April 2 IFR on the Paycheck Protection Program (PPP). On June 5, 2020, the Paycheck Protection Program Flexibility Act of 2020 (Flexibility Act) was signed into law, amending the CARES Act. This interim final rule changes key provisions, such as the loan maturity, deferral of loan payments, and forgiveness provisions, to conform to the Flexibility Act. SBA also is […]

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 […]

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 […]

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 […]