The effects of the COVID-19 pandemic are being felt across the financial services sector. Regulatory agencies, financial institutions, service providers, and consumers have been impacted. With staff and employees of government agencies and private sector companies working remotely, impacts to consumer employment and income, and many other pandemic related consequences, industry participants face a host of compliance issues and legal risks.
While we appreciate that our scope will not be exhaustive, Venable's Financial Services Practice is continuing to provide coverage and analysis of legal and regulatory topics and guidance, and our team will be sorting through and analyzing the regulatory announcements to help industry participants find the answers they need.
Many of the articles in this edition of the Consumer Financial Services Practice Digest are COVID-19 related. Please also read our overview of the COVID-19 issues we will be following in the weeks ahead.
Consumer Financial Services Legal & Regulatory Update: COVID-19
March 25, 2020 | Webinar
Members of Venable’s Consumer Financial Services Practice Group will address the latest on the evolving legal and regulatory landscape, and ways to manage key compliance risks, related to the fallout from the COVID-19 pandemic.
As the consumer financial services sector is adapting and responding to the needs of consumers, meeting technological and operational requirements, and adhering to legal and compliance requirements, companies should be aware of how federal and state regulatory agencies are continuing, and, in some cases, adapting their policy agendas, supervisory and examination programs, and enforcement focus, and how to avoid unfair, deceptive, and abusive practices or fail to adhere to new requirements that could increase legal risk.
Contents:
Federal Regulators Look to Banks to Help Meet COVID-19 Challenges: A Summary and Complete Timeline
Compliance Tips for Remote Work During COVID-19
HUD/FHFA Halt Foreclosures and Evictions for 60 Days in Response to COVID-19
Debt Collection Rulemaking Comment Period Extended Due to COVID-19
Fintech and Online Lending Legal and Policy Issues
Federal Regulators Look to Banks to Help Meet COVID-19 Challenges: A Summary and Complete Timeline
The federal government and banking agencies are calling on financial institutions to take the lead in helping to mitigate the damage from COVID-19 to consumers, businesses, and our economy. The agencies are acting with urgency, and over the past two weeks they have issued numerous statements, guidance and FAQ documents, and rules, all targeted at providing banks with the tools to meet customers' financial needs during this stressful time. Through a combination of enhanced credit resources and regulatory relief, the banking agencies are strongly encouraging banks to work with affected customers to provide lending, liquidity, and other financial services.
Compliance Tips for Remote Work During COVID-19
As we continue to react to the COVID-19 pandemic, financial services companies with consumer-facing operations have seen a sudden and substantial increase in the number of employees who are working remotely. This, in turn, brings with it unique compliance challenges, including (1) avoiding UDAAP challenges; and (2) licensing requirements.
HUD/FHFA Halt Foreclosures and Evictions for 60 Days in Response to COVID-19
In a continued effort to alleviate the impact of the coronavirus emergency, the U.S. Department of Housing and Urban Development has authorized the Federal Housing Finance Agency (FHFA) to direct Fannie Mae and Freddie Mac (the GSEs) to suspend foreclosures and evictions for 60 days. The suspension applies to homeowners with a GSE-backed single-family mortgage. This follows FHFA's announcement from earlier this month providing forbearance for up to 12 months as an option to borrowers impacted by the coronavirus.
Debt Collection Rulemaking Comment Period Extended Due to COVID-19
The Consumer Financial Protection Bureau (CFPB) announced that the comment period on its Supplemental Notice of Proposed Rulemaking (SNPRM) implementing the Fair Debt Collection Practices Act (FDCPA) will be extended to June 5, 2020, given the challenges posed by the COVID-19 pandemic.
Resources
Venable's COVID-19 Resources
Explore our collection of timely and relevant alerts, webinars, and news as global preparations for the impact of COVID-19 continue.
Fintech and Online Lending Legal and Policy Issues
LEND360 held its first annual Online Lending Legal and Policy Issues Forum on February 26, 2020, at Venable’s Washington, DC office. The conference focused on the legal issues facing online lenders and fintech firms. For a collection of timely and relevant alerts and webinars on fintech and online lending topics, please click here.