The RESPONSE: Federal and State Actions Affecting the Financial Services Sector – Edition 2 | Holland & Knight LLP


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Like our clients, Holland & Knight’s Financial Services Industry Group is committed to actively contributing to our country’s response to the Coronavirus (COVID-19) pandemic and economic fallout and related recovery efforts. For our part, Holland & Knight’s 300 and more the lawyers and professionals who make up our financial services industry group want to ensure that bank and non-bank financial institutions, financial intermediaries and other participants and stakeholders in the financial services industry have access to updates timely, accurate and succinct updates on federal and state laws, regulations and administration. responses to the COVID-19 pandemic that are most relevant to our financial services customers.

To that end, we are happy to share with you the latest edition of The RESPONSE.

Federal regulators encourage small loans

Five Federal Financial Regulatory Agencies Release Joint Statement on March 26, by encouraging banks, savings associations and credit unions to offer responsible low-value loans to consumers and small businesses in response to COVID-19, which loans can be offered through a variety of structures, including appropriately structured open credit lines, fixed maturity loans or single payment loans. In the joint statements, the agencies encouraged banks, savings associations and credit unions to consider recovery strategies designed to help borrowers who experience unforeseen circumstances and cannot repay a loan as structured to be. able to repay the loan principal while reducing the need to re-borrow.

Federal and state regulators offer regulatory reporting exemption

the Federal Reserve Announcement on March 26, that it will not take legal action against a financial institution with total assets of $ 5 billion or less for the submission of its consolidated financial statements for bank holding companies as of March 31, 2020 (FR Y- 9C) or financial statements of US non-bank subsidiaries of US Bank Holding Companies (FR Y-11) after the official filing deadline, provided the applicable report is submitted within 30 days of the official filing deadline . the OCC issued a similar statementt the following March 25 an announcement from the FFIEC highlighting coordination and collaboration among its members to fight COVID-19.

FDIC Announces Temporary Alternative Procedures for Sending Supervisory-Related Correspondence

March 26, FDIC issued letter regarding financial institutions establish temporary measures for financial institutions and other parties that electronically submit mail and electronic mail for official business purposes related to supervisory matters.

Texas Financial Services Regulators Encourage Loan Changes

On March 26, the Texas Office of Consumer Credit Commissioner released a series of revised bulletins urging regulated licensees to work with consumers affected by COVID-19, including developing contract changes. The bulletins below provide additional information to make doing business easier during the crisis:

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