The “Consolidated Appropriations Act, 2021” (CAA), which includes provisions designed to mitigate the ongoing economic fallout of COVID-19, became law on December 27, 2020. While most of the public’s attention is on other of the CAA ’s benefits —like direct
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Oregon Governor Issues Executive Order Related to Foreclosure Moratorium
On December 17, 2020, Governor Kate Brown issued an executive order related to Oregon’s foreclosure moratorium (HB 4204). Under Executive Order 20-67 (EO 20-67), Governor Brown determined that a state of emergency continues to exists in the State of Oregon
Oregon Presses Pause on Foreclosures, Payment Defaults, and Evictions
In an effort to provide relief to homeowners, businesses, landlords, and tenants affected by COVID-19, Governor Brown signed two bills that impose significant limitations on lenders and landlords. Under HB 4204, lenders cannot foreclose on loans secured by real estate
At Long Last, FinCEN Offers Much Awaited Guidance Regarding BSA Due Diligence Requirements for Hemp Businesses
Ever since Congress passed the 2018 Farm Bill and hemp was declassified under federal law as a Schedule I controlled substance, financial institutions have struggled with whether and how to bank the hemp industry. Many bankers simply feared that the
“First Come, First Served:” SBA Issues Critical Guidance for Payroll Protection Program Loans
The Small Business Administration (SBA) has issued an Interim Final Rule controlling how $349 billion in short-term business loans under the CARES Act will be allocated. While the SBA is seeking comments from the public, the rule is effective immediately
CARES Act Amends Bankruptcy Code to Address COVID-19 Dislocation
Section 1113 of the CARES Act amends certain provisions of the Bankruptcy Code and will apply to the year following the date on which this new law goes into effect. These changes are primarily designed to benefit small businesses and
Federal Banking Agencies Encourage Small-Dollar Lending
No, your eyes aren’t deceiving you. On Thursday, March 26, 2020, the federal banking agencies (i.e., the FDIC, CFPB, FRB, NCUA, and OCC) issued a joint statement encouraging banks and credit unions to offer responsible small-dollar loans to consumers and
Congress CARES: Federal Stimulus Package to Provide Emergency Relief to Borrowers and Financial Institutions
On Wednesday, March 25, 2020, the Senate unanimously passed a $2 trillion economic stimulus package. Called the Coronavirus Aid, Relief, and Economic Security (or CARES) Act, this unprecedented bill is expected to be passed by the House this Friday and
CARES Act Expands Small Business Lending and Provides Potential Loan Forgiveness
In its current form, the CARES Act amends the Small Business Administration’s (SBA) Section 7(a) loan program to encourage banks and credit unions to make small business loans under what is known as the “Paycheck Protection Program.” If passed, the
Banking Regulators Encourage Lenders to Work with Borrowers Impacted by COVID-19
Federal banking regulators took a bold, first step this past Sunday, announcing Interagency Guidance (“the Guidance”) to encourage lenders to work with borrowers impacted by the COVID-19 outbreak.[1] The Guidance specifically permits lenders to enter into (prudent, of course)