Under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, special rules were implemented to provide relief to Americans impacted by the pandemic. This relief includes providing easier access to retirement and IRA funds for those who need it through special distribution options and rollover rules, as well as permissible loans from certain retirement plans. The 14 Q&As released by the IRS addresses questions by both individuals and administrators related to the relief for retirement […]
Tag: Coronavirus
CORONA RELIEF – ECOA VALUATION RULE
On April 29, 2020 the Consumer Financial Protection Bureau (CFPB) published a Compliance Aid dealing with the ECOA Valuation Rule. The Aid, which is in Question/Answer format, was effective upon publication. QUESTION 1: Under the Equal Credit Opportunity Act (ECOA) and its implementing Regulation B, creditors are required to provide applicants for first-lien loans on a dwelling with copies of appraisals, as well as other written valuations (collectively, “valuations”), developed in connection with the application […]
CORONA RELIEF – TRID AND RESCISSION WAITING PERIODS
On April 28 the Consumer Financial Protection Bureau (CFPB) released an Interpretative Rule that concludes that a consumer has a “bona fide personal financial emergency” if the consumer determines that his or her need to obtain funds due to the COVID-19 pandemic Necessitates consummating the credit transaction before the end of the TRID Rule waiting periods or Must be met before the end of the Regulation Z Rescission Rules waiting period. Under such circumstances the […]
REGULATION O MODIFIED FOR PPP LOANS
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 […]
FEDERAL RESERVE BOARD’S PANDEMIC RELIEF EFFORTS
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 […]