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
On May 22, 2020 the Small Business Administration (SBA) and the Department of Treasury jointly issued two interim final rules (IFR) related the Paycheck Protection Program (PPP). The first IFR deals with Loan Forgiveness; the second covers Loan Review Procedures and Related Borrower and Lender Responsibilities. Loan Forgiveness – The 26-page IRF on Loan Forgiveness is designed to: Help PPP borrowers prepare and submit loan forgiveness applications as provided for in the CARES Act; Help
On May 20, 2020 the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the National Credit Union Administration jointly issued the Interagency Lending Principles for Offering Responsible Small-Dollar Loans. The agencies: Recognize the important role that responsibly offered small-dollar loans can play in helping customers meet their ongoing needs for credit from temporary cash-flow imbalances, unexpected expenses, or income shortfalls, including during periods of economic stress,
News has been leaking all week, now it is official: The Office of the Comptroller of the Currency (OCC) is publishing a final Community Reinvestment Act (CRA) rule today; Comptroller of the Currency Joseph Otting is resigning tomorrow; and The Federal Deposit Insurance Corporation is not joining the final CRA rule at this time. That leaves many unanswered questions, including what happens next to CRA?
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.
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