Williams Mullen's COVID-19 Comeback Plan: Preparing Today for Tomorrow's PPP Audit
On September 19, 2024, the District Court for the Eastern District of New York dismissed claims against the mortgage lender, its mortgage servicer, and credit reporting agencies under the Fair Credit Reporting Act (FCRA), 15...more
Employers now have a new benefit option in their toolbelt: The Qualified Student Loan Payment (QSLP) match. But is it worth implementing? Before diving into the specific legal requirements for a QSLP match program, this...more
On September 24, the CFPB announced the release of its annual report on the most pressing financial concerns facing servicemembers. This edition highlights that servicemembers are encountering student debt-related...more
Seyfarth Synopsis: On August 19, 2024, the IRS issued Notice 2024-63 (the “Notice”) providing guidance for plan sponsors that wish to provide matching contributions based on eligible student loan repayments made by...more
On March 5, 2024, the Supreme Court of the State of New York, ruled that an obvious scriveners error in a guaranty, exempting a guarantor from full recourse liability for the loan’s debt, could be corrected to impose personal...more
The Department of Veterans Affairs (VA) made significant changes to its loss mitigation program this month, launching its awaited Veterans Affairs Servicing Purchase Program, and implementing a 40-year loan modification term....more
As federal student loan repayments resume after a three-year pause due to the COVID-19 pandemic, the Consumer Financial Protection Bureau (CFPB) published an Issue Spotlight on student borrowers’ experiences, using consumer...more
Heads I Win, . . . - When closely held corporations that are under common control engage in any intercompany transaction, it is prudent for the corporations and their shareholders to ensure that the transaction is being...more
Student loan debt is a significant source of financial stress for borrowers, who face a hefty new line item in their budgets since the pause on student loan repayment ended in October 2023. Recent surveys show that student...more
With the onset of the COVID-19 pandemic, Congress initiated several programs to help businesses weather the difficult economic conditions. The Coronavirus Aid, Relief, and Economic Security (CARES) Act provided two of these...more
On November 1, the OCC issued Bulletin 2023-34 addressing the topic of “venture lending,” referred to as “commercial loans to early-, expansion-, and late-stage companies.” According to the Bulletin, venture lending is often...more
Welcome to the October edition of the UK Tax Round Up. This month has seen the Supreme Court’s judgment on the operation of the employment-related securities deeming provision, the Court of Appeal’s decision on what...more
This year, the federal government’s new health equity regulations began taking effect. The regulations represent the government’s increased commitment to health equity advancement as a major part of its regulatory...more
On July 27, the Consumer Financial Protection Bureau (CFPB) released a new blog post, positing that cashflow data, broadly defined as the various inflows, outflows, and accumulated amounts in a consumer’s checking and savings...more
On June 29, 2023, a new interagency Policy Statement (the Statement) was issued relating to commercial real estate (CRE) loan accommodations and workouts. The Statement is relevant to all financial institutions governed by...more
Last week, the Federal Trade Commission (FTC) obtained temporary restraining orders against two student debt relief companies in the U.S. District Court for the Central District of California. The FTC thereby temporarily...more
Today’s high interest rate environment presents a challenge to many commercial real estate borrowers whose loans are now reaching maturity. Some borrowers are unable to repay their loans, while others are approaching the loan...more
The Federal Housing Administration recently issued Mortgagee Letter 2022-23, establishing a new COVID-19 Home Equity Conversion Mortgage Property Charge Repayment Plan. The COVID-19 HECM Property Charge Repayment Plan would...more
On February 13, a coalition of state attorneys general led by California and Massachusetts submitted a letter in support of the Department of Education’s (DOE) proposed changes to income-driven repayment plans (IDR) for...more
The Health Resources & Service Administration (“HRSA”) has begun issuing Final Repayment Notices to providers who received Provider Relief Funds (“PRF”) under the following circumstances: Providers who rejected the Terms and...more
On December 22, the Department of Education announced a 90-day extended pause on student loan repayment, interest, and collections through May 1, 2022, which will allow the Biden Administration “to assess the impacts of the...more
The Department of Labor recently proposed updates to its Voluntary Fiduciary Correction Program (VFCP), which would allow fiduciaries the opportunity to self-correct certain matters including late deposits to a 401(k) plan....more
On September 8, 2022, the U.S. Court of Appeals for the Second Circuit reversed a judgment entered for a group of lenders (or their representatives) of cosmetics company Revlon, Inc. in a case over entitlement to $500 million...more
As millions of student loan borrowers await further details on President Biden’s student loan relief, your employees likely have student loans on the brain. Now is a good time to review the available options for providing...more
On September 26, 2022, the IRS released IRS Notice 2022-45, which corrected a potential oversight in IRS Notice 2022-33, discussed in detail here. Notice 2022-33 had extended the deadline to adopt certain retirement and...more