Another day, another major pronouncement from the Consumer Financial Protection Bureau (CFPB or Bureau), which just took two important actions. First, it rescinded seven different policy statements that offered flexibility to...more
What happened -
On June 16, 2020, the Bureau of Consumer Financial Protection (CFPB) released a Compliance Aid in the form of ten FAQs (FAQs) on consumer reporting related to the CARES Act and the COVID-19 pandemic. The...more
On May 20, 2020, the U.S. Court of Appeals for the Seventh Circuit sided with a lower court which invalidated applying the “Ineligibility Rule” by the Small Business Administration (SBA) to the Paycheck Protection Program...more
On May 15, 2020, the Small Business Administration (SBA) published a form of the loan forgiveness application for borrowers of Paycheck Protection Program (PPP) loans under the CARES Act. The application provides instructions...more
In a significant rebuke of the Small Business Administration (SBA), a Michigan federal district court has rejected the SBA’s attempt to deem a number of applicants, including sexually oriented dance clubs, ineligible for...more
5/21/2020
/ Administrative Procedure Act ,
Amended Complaints ,
CARES Act ,
Chevron Deference ,
Congressional Intent ,
Coronavirus/COVID-19 ,
Eligibility ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Preliminary Injunctions ,
SBA Lending Programs
On May 4, 2020, three Paycheck Protection Program (PPP) borrowers that received $750,000 in first-round funding sued the Small Business Administration (SBA) and the Treasury Department in the U.S. District Court, Central...more
While predicting the enforcement priorities of the financial regulators has always been more of an art than a science, the current circumstances—including a pandemic, a presidential election and a Supreme Court case hanging...more
Highlights:
- Program reauthorized for $310 billion and intended to be more widely distributed
- Bad news for venture capital and private equity
- Good news for hospitals and gaming
- Renewed focus on the...more
Residential mortgage servicers have now received critical new guidance regarding borrowers adversely impacted by COVID-19. In the first guidance, on April 3, the CFPB, the Federal Reserve, the FDIC, the NCUA, the OCC and...more