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
The Treasury Department has recently published the Paycheck Protection Program Loans Frequently Asked Questions (PPP FAQs). The Treasury Department’s publication provides businesses and lenders desperate guidance related to...more
4/9/2020
/ Affiliated-Business Arrangements ,
Affiliates ,
Board of Directors ,
Business Interruption ,
CARES Act ,
Core Funding Ratio (CFR) ,
Coronavirus/COVID-19 ,
Economic Injury Disaster Loans ,
Electronic Records ,
Employee Retention ,
Executive Compensation ,
Federal Loans ,
Financial Stimulus ,
Health Insurance ,
Lenders ,
Paycheck Protection Program (PPP) ,
Payroll Taxes ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Shareholders ,
Small Business ,
Stocks ,
Tax Relief
In a Policy Statement effective on January 24, 2020, the CFPB addresses perceived uncertainty as to the scope and meaning of the abusiveness standard, and that the CFPB had in various enforcement actions asserted claims for...more
1/27/2020
/ Banking Sector ,
Civil Monetary Penalty ,
Consumer Financial Protection Bureau (CFPB) ,
Disgorgement ,
Dodd-Frank ,
Enforcement Actions ,
Financial Services Industry ,
Good Faith ,
Policy Statement ,
Safe Harbors ,
Unfair or Deceptive Trade Practices
On December 12, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) issued a proposed rule that would result in major changes to the rules applying the Community...more
12/16/2019
/ Banking Sector ,
Comment Period ,
Community Reinvestment Act ,
Depository Institutions ,
FDIC ,
Federal Reserve ,
Low Income Housing ,
OCC ,
Proposed Rules ,
Regulatory Standards ,
Small Banks
On November 19, the Federal Deposit Insurance Corporation issued a Notice of Proposed Rulemaking (FDIC Notice) setting forth a proposed rule that, if ultimately adopted, would confirm that the “valid-when-made” doctrine...more
Having a well-drafted contract is one of the most important acts you can take to minimize your risks. As such, you should consider including in your next contract a limitation of liability for consequential and punitive...more
The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation issued a Notice of Proposed Rulemaking (Notice) that would affirm that when a national bank or savings association sells, assigns, or...more
11/19/2019
/ Assignments ,
Comment Period ,
Consumer Lenders ,
FDIC ,
Interest Rates ,
Loans ,
NPRM ,
OCC ,
Proposed Rules ,
Sale of Assets ,
Valid When Made Doctrine
Today, the Alternative Reference Rates Committee (ARRC) released “ARRC RECOMMENDATIONS REGARDING MORE ROBUST LIBOR FALLBACK CONTRACT LANGUAGE FOR NEW CLOSED-END, RESIDENTIAL ADJUSTABLE RATE MORTGAGES” (Recommendations)...more
On Monday, October 28, Attorney General William Barr and Department of Housing and Urban Development Secretary Ben Carson signed a memorandum of Understanding (MOU) between the Department of Justice (DOJ) and HUD. The MOU...more