Category Archives: COVID-19 (Coronavirus)

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CFPB Offers Flexibility for Responding to Credit Reporting Disputes During COVID-19 Pandemic — But Private Litigants May Not

The CFPB’s April 1, 2020, statement regarding credit reporting for loans affected by COVID-19 announced a “flexible supervisory and enforcement approach during this pandemic.” In addition to guidance regarding furnishing obligations while consumers are impacted by COVID-19, the bureau specifically announced relaxed enforcement standards for companies struggling to respond to consumer credit disputes within the … Continue Reading

Credit Reporting Requirements and COVID-19 – CFPB and FHA Weigh In

We’ve been tracking regulatory developments related to credit reporting for loans where borrowers have been affected by the coronavirus outbreak. On April 1, the CFPB issued a statement about credit reporting for loans affected by COVID-19. The statement announces the CFPB’s “flexible supervisory and enforcement approach during this pandemic” and seeks to reassure credit reporting … Continue Reading

Mortgage Servicers: Keep an Eye on the CFPB’s Advice to Borrowers Impacted by COVID-19

On March 31, 2020, the CFPB posted a “Guide to coronavirus mortgage relief options,” which provides instruction to mortgage loan borrowers who may be impacted by COVID-19 on when and how to go about obtaining assistance. While we have previously discussed compliance challenges that are likely to arise related to verbal loss mitigation applications and … Continue Reading

Federal Reserve Implements Aggressive Liquidity Campaign as Growing Corporate Debt Threatens to Exacerbate COVID-19 Economic Toll

In response to the recent COVID-19 outbreak, Congress recently approved a $2 trillion stimulus package in an attempt to offset the potentially disastrous economic effects of COVID-19. Meanwhile, central banks are implementing increasingly drastic measures aimed at preserving the availability of capital during the looming recession, which appears increasingly imminent as the global economy remains … Continue Reading

Federal Reserve Acts to Bolster Auto Finance, Credit Card, Student Lending Industries

In an action somewhat lost amidst the unprecedented $2 trillion Coronavirus Aid, Relief, and Economic Security Act (CARES Act), the Federal Reserve’s Board of Governors announced a series of five “extensive new measures” to provide liquidity for certain sectors of the nation’s economy. One of those liquidity facilities, the reintroduced Term Asset-Backed Securities Loan Facility … Continue Reading

Coronavirus Economic Stabilization Act of 2020: Implications for Consumer Financial Services

On Friday, President Trump signed the Coronavirus Economic Stabilization Act of 2020 (CARES Act). The significant legislation directs more than $2 trillion into fighting the COVID-19 pandemic and stimulating America’s economy for the duration of the pandemic. This blog summarizes some of the provisions that are most relevant to financial institutions that make or service … Continue Reading

Congress’ Third Major Coronavirus Legislation Makes Bankruptcy Relief for Potential and Current Individual Debtors Easier

On Friday March 27, 2020, President Trump signed into law the third major piece of coronavirus-related legislation in the last several weeks – the Coronavirus Aid, Relief, and Economic Security Act (CARES). The new law contains several amendments to the Bankruptcy Code. One of these amendments increases the maximum indebtedness for a “small business debtor” … Continue Reading

CFPB Eases Reporting Requirements

On March 26, the CFPB announced an easing of certain reporting requirements in order to allow financial services companies to focus on responding to consumers during the COVID-19 pandemic. The CFPB postponed several different reporting requirements relating to the Home Mortgage Disclosure Act (HMDA), credit cards, and prepaid accounts. In an unusual step for the … Continue Reading

Federal Regulatory Agencies Offer Interagency Statement Regarding COVID-19-Related Loan Modifications and Status Reporting

The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, the Consumer Financial Protection Bureau, and the Conference of State Bank Supervisors issued an Interagency Statement on March 22 urging regulated financial institutions to work with borrowers affected … Continue Reading

Fannie Mae and Freddie Mac Announce Relief Plan for Multifamily Borrowers

On Tuesday, Fannie Mae and Freddie Mac, in coordination with the Federal Housing Finance Agency, announced relief plans to discourage multifamily landlords from evicting renters from properties as a result of non-payment. In exchange, Fannie Mae and Freddie Mac are allowing multifamily landlords (whose loans are financed by Freddie or Fannie) to defer loan payments … Continue Reading

Updates from 12 State Regulatory Agencies Regarding Coronavirus and Related Work from Home Issues

As regulatory agencies provide guidance regarding working from home for financial services professionals while the COVID-19 outbreak progresses, we summarized the additional guidance issued in the recent past and current as of March 24, 2020. California Department of Real Estate Released Frequently Asked Questions Relating to COVID-19 The California Department of Real Estate’s Frequently Asked … Continue Reading

Bankruptcy, Coronavirus (COVID-19), and How Retailers Can Brace for the Impact

The brick-and-mortar retail industry has been in a state of flux since online retailers such as Amazon started business in the mid-‘90s. Recent years have been particularly difficult for retailers: in 2018, retailers represented 5 of the 10 largest Chapter 11 bankruptcies. The pace of retail bankruptcies showed no signs of slowing in 2019, with … Continue Reading

What Will COVID-19 Relief Look Like and How Will It Affect Financial Services Companies?

Both parties have recognized the need for significant and immediate relief to assist consumers and small businesses affected by COVID-19. On March 18, 2020, Rep. Maxine Waters (D-CA), the chairwoman of the House Financial Services Committee, released plans for responding to the COVID-19 pandemic. At this point, the plans are merely a high-level list of … Continue Reading

COVID-19 and the Mortgage Industry: 7 Things We Know Today

Operating a financial institution is always a challenge, but the COVID-19 outbreak has triggered a unique set of overlapping and sometimes conflicting concerns for mortgage originators and servicers. Here is what we know as of March 20: On March 18, 2020, HUD issued Mortgagee Letter 2020-04, announcing a 60-day moratorium for foreclosures and evictions, effective … Continue Reading

Mortgage Servicing Compliance Challenges Associated with Verbal Loss Mitigation Applications, Short-Term Repayment and Forbearance Plans Will Be Amplified by COVID-19

While paying attention to the CFPB’s guidance in its Supervisory Highlights reports is always important, in the midst of the COVID-19 pandemic it is now critical that mortgage servicers be mindful of the loss mitigation violations that were described in the Winter 2020 edition. In its Winter 2020 Supervisory Highlights report, the CFPB described several … Continue Reading

How Is the COVID-19 Pandemic Impacting the Student Lending Industry?

Like the country and economy at large, the COVID-19 pandemic is significantly impacting secondary education and the student lending industry. In response to the pandemic, colleges across the country closed their campuses, sent students home, and turned to online learning platforms, creating uncertainty for current student borrowers. President Trump, Congress, and the U.S. Department of … Continue Reading

Four Additional States Issue New Guidance Relating to Working from Home; Massachusetts and New York Supplement Previous Guidance

As we continue to follow the trend of regulatory agencies providing guidance allow working from home for financial services professionals while the COVID-19 outbreak progresses, we summarized the additional guidance issued in the recent past and current as of March 19, 2020. Colorado Department of Regulatory Agencies, Division of Real Estate Issued an Advisory on … Continue Reading

Credit Reporting During the COVID-19 Outbreak: Fannie Mae and the VA Offer New Guidance

We previously blogged about the push among lawmakers and regulators to encourage or force financial institutions to cease providing adverse credit reporting on consumer loans where the delinquency or default may be related to the outbreak of COVID-19. Given the rapidly changing environment, it is not surprising that there have been some material changes in … Continue Reading

HUD, Fannie Mae, and Freddie Mac Suspend Foreclosures and Evictions for 60 Days

During a COVID-19 press briefing at the White House on March 18, 2020, President Donald Trump announced that the Department of Housing and Urban Development (HUD) will temporarily suspend “all foreclosures and evictions.” The president made this announcement to provide “immediate relief” to homeowners and renters struggling to make rent and mortgage payments. The president’s … Continue Reading

COVID-19 Ripple Effects Are Coming – Lenders Must Get Ready

The coronavirus pandemic is affecting businesses large and small. Now is the time for lenders to prepare for its effect on business borrowers. Industries Already in Distress In February, a PricewaterhouseCoopers (PwC) report identified five industry sectors likely to see the greatest restructuring activity in 2020: Energy Retail Dining and food service Auto suppliers Specialty … Continue Reading

How to Handle Credit Reporting for Consumer Loans That Are Delinquent or in Default Due to COVID-19 Related Delays

Although the major federal banking and consumer lending regulatory industries have issued a joint statement indicating “that financial institutions should work constructively with borrowers and other customers in areas affected by COVID-19,” there are open questions regarding whether financial institutions should change their normal policies and procedures for furnishing credit reporting information regarding the status … Continue Reading

Update March, 18 2020: Financial Services Licensing and Compliance Obligations and COVID-19

As members of the financial industry prepare to meet the challenges associated with COVID-19, key government agencies have begun to offer guidance with respect to how their regulated financial institutions, including non-depositories, can meet their compliance obligations while balancing the realities of a pandemic event due to COVID-19. This blog summarizes the updates that we … Continue Reading

Update March 13, 2020: Financial Services Licensing and Compliance Obligations and COVID-19

As members of the financial industry prepare to meet the challenges associated with COVID-19, key government agencies have begun to offer guidance with respect to how their regulated financial institutions, including non-depositories, can meet their compliance obligations while balancing the realities of a potential pandemic event due to COVID-19. This blog summarizes the latest updates … Continue Reading

Financial Services Licensing and Compliance Obligations and COVID-19

As members of the financial industry prepare to meet the challenges associated with COVID-19, key government agencies have begun to offer guidance with respect to how their regulated financial institutions, including non-depositories, can meet their compliance obligations while balancing the realities of a potential pandemic event due to COVID-19. This blog summarizes the updates that … Continue Reading
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