California has enacted a new California Consumer Protection Law (CCFPL), California Financial Code Section 90001 et seq. The CCFPL will convert the Department of Business Oversight (DBO) into a new Department of Financial...more
9/11/2020
/ Bank Holding Company ,
Banks ,
California ,
Covered Person ,
Credit Unions ,
Debt Collection ,
Exemptions ,
Farm Credit Administration ,
FinTech ,
Governor Newsom ,
Savings and Loan Companies ,
Third-Party Agents ,
Trusts ,
UDAAP
The Centers for Disease Control and Prevention has issued an order titled “Temporary Halt in Residential Evictions To Prevent the Further Spread of COVID-19” (“Order”) forbidding evictions of residential tenants who do not...more
9/8/2020
/ CARES Act ,
Centers for Disease Control and Prevention (CDC) ,
Coronavirus/COVID-19 ,
Economic Impact Payments ,
Eviction ,
IRS ,
Landlords ,
Loss of Income ,
Moratorium ,
New Guidance ,
Property Owners ,
Public Health Service (PHS) ,
Relief Measures
On August 27, HUD announced that it is extending its Covid-related foreclosure and eviction moratoriums for FHA insured loans set to expire on August 31, until December 31, 2020, and issued a Mortgagee Letter implementing the...more
On August, 18, 2020, the CFPB issued a new proposed rule to create a new category of “seasoned qualified mortgages” (Seasoned QMs) that would receive the safe harbor conclusive presumption of meeting the Ability to Repay...more
On July 31st the Federal Reserve posted amended versions of a number of Main Street Lending Program (MSLP) transaction documents, including the Frequently Asked Questions (FAQs) and Term Sheets for MSLP. Many of the changes...more
On July 28, the Federal Reserve announced that many of its emergency lending facilities, including the Main Street Lending Program’s New Loan Facility, Priority Loan Facility, Expanded Loan Facility, Nonprofit Organization...more
On July 23, SBA announced that lenders may begin submitting PPP loan forgiveness requests to SBA on August 10. To assist lenders, SBA issued a Procedural Notice with new guidance regarding lenders’ reviews of forgiveness...more
The Federal Reserve has announced that the Main Street Lending Program will now be available to non-profits such as educational institutions, hospitals, and social service organizations, and has issued a set of Frequently...more
On July 20, the Office of the Comptroller of the Currency proposed a rule which, if finalized as a rule, would establish a new standard for when a national bank or Federal savings association (“bank”) is the “true lender” in...more
On July 15, 2020, the Federal Reserve published a number of changes to the Main Street Lending Program’s frequently asked questions, which FAQs were amended to provide further guidance on a number of issues. The Federal...more
On June 8, the Federal Housing Finance Agency (FHFA) announced that it is extending the available date of certain Covid-19 related origination process flexibility modifications for Fannie Mae and Freddie Mac customers. These...more
Wednesday evening, July 1, the House by unanimous voice vote passed a bill already approved unanimously by the Senate that will extend the period to obtain PPP loans until August 8, 2020. President Trump is expected to sign...more
To implement the changes to the PPP program contained in the recently enacted PPP Flexibility Act, Treasury has issued a new Interim Final Rule (IFR). It has also issued a revised forgiveness application form, worksheet and...more
On June 8, the Federal Reserve announced a number of changes to the Main Street Lending Program (“MSLP”), involving all three facilities, the Main Street New Loan Facility (“MSNLF”), the Main Street Priority Loan Facility...more
On June 5, the President signed the PPP Flexibility Act. As first described in Buchalter’s previous ALERT, this new law creates the following adjustments to PPP requirements:
For loans entered into on or after the date the...more
On June 4, the Consumer Financial Protection Bureau (CFPB) took steps to provide rules and guidance for the upcoming transition away from LIBOR for adjustable rate loans. The CFPB issued the following:
A revised version...more
By a near-unanimous 417-1 vote, the House has passed the PPP Flexibility Act, which if enacted would, among other things, extend the time to utilize Payroll Protection Program (PPP) loan proceeds and obtain forgiveness,...more
On May 27, the Alternative Reference Rates Committee (ARCC) published recommendations for the transition from LIBOR in different financial transactions, including residential mortgage transactions. Given prior pronouncements...more
On May 20, 2020, the Office of the Comptroller of the Currency (OCC) issued as new final rule updating various aspects of the requirements of the Community Reinvestment Act (CRA). The rule is effective on October 1, 2020....more
On May 22, Treasury issued a new Interim Final Rule (“IFR”) regarding Small Business Administration (“SBA”) Payroll Protection Program (”PPP”) loan forgiveness. Much of the IFR repeats information previously published by...more
The Treasury Department has issued a form application to be used for SBA Payroll Protection Program (PPP) borrowers to seek loan forgiveness, along with instructions for completing the form and an accompanying worksheet... ...more
The Federal Reserve has published more detailed information about the soon to be launched Main Street Lending Program (MSLP) designed to assist businesses with up to 10,000 employees or up to $2.5 billion of annual revenue...more
On April 16, the CFPB issued a HMDA final rule increasing the number of closed-end mortgage loans and/or open-end mortgage loans an institution must originate before it meets HMDA’s coverage thresholds. Effective July 1,...more
Governmental and GSE responses to the COVID-19 crisis continue at a rapid pace. Just within the last few days, new guidelines have been issued regarding several multifamily and single family residential topics. These new...more
In a major development to assist businesses with up to 10,000 employees or up to $2.5 billion of annual revenue which have been impacted by the COVID-19 pandemic, the Federal Reserve has issued Term Sheets for the two...more