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 under the Truth in Lending Act, its implementing Regulation Z, and the Electronic Signatures in Global and National Commerce Act. The CFPB’s Statement provides temporary supervisory and enforcement flexibility for credit card… Read More
This client alert provides an overview of three recent CFPB guidance documents highlighting existing regulatory flexibility and responsibilities for financial institutions when interacting with consumers in the context of the COVID-19 pandemic: A statement notifying credit card issuers and other open-end creditors that the CFPB will provide supervision and enforcement flexibility during the pandemic with… Read More
On April 13, 2020, the Consumer Financial Protection Bureau issued an interpretive rule to provide guidance to government agencies, including the U.S. Department of the Treasury, to make COVID-19-related relief payments to individuals, including the economic impact payments authorized in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). According to a press release,… Read More
On March 27, 2020, President Trump enacted a historic stimulus package, the CARES Act, which contains a number of provisions of interest to the financial services industry. This alert provides an overview of the financial services-related provisions of the new law. Read our client alert.
As consumers and business face ever-worsening financial conditions in the wake of the COVID-19 pandemic, federal agencies and some states and localities have stepped in to provide foreclosure and eviction relief. Not surprisingly, the approaches to providing this relief vary greatly, creating significant operational challenges for servicers operating in multiple jurisdictions. We discuss below these… Read More