Archive

SBA PPP LOAN FORGIVENESS

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.

CFPB ISSUES COVID-19 PAYMENT AND DEPOSIT FAQS

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

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 […]

FLOOD INSURANCE COMPLIANCE IN RESPONSE TO THE CORONAVIRUS

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 […]

REGULATION B – CLARIFICATION FOR PPP LOANS

On May 6 the Consumer Financial Protection Bureau (CFPB) issued three clarifying Frequently Asked Questions ( FAQs) to support small businesses who have applied for a loan from their financial institution under the Small Business Administration’s (SBA) Paycheck Protection Program (PPP). Question 1. – Creditors are generally required under the Equal Credit Opportunity Act and Regulation B to notify applicants within 30 days of receiving a “completed application” of the creditor’s approval, counteroffer, denial or […]