Pennsylvania’s Attorney General Josh Shapiro announced this week that his office has launched “PA CARE Package,” a consumer relief program for PA consumers impacted by the COVID-19 pandemic. The program is intended to implement and expand on the consumer protections provided by the federal CARES Act.  The press release issued by the PA AG’s Office describes the program as a partnership between the PA AG’s Office and banks and financial institutions in PA to offer…

The CFPB has published a request for information (RFI) in today’s Federal Register seeking comments and information to assist its Taskforce on Federal Consumer Financial Law.  Comments on the RFI must be received by June 1, 2020. The CFPB created the Taskforce in October 2019 to examine ways to harmonize and modernize federal consumer financial laws.  The Taskforce is charged with examining the existing legal and regulatory environment for consumers and financial services providers and…

On March 26, the CFPB issued three policy statements designed to provide flexibility to banks and financial services companies to allow them to focus on responding to customers in need during the COVID-19 pandemic. First, in two separate policy statements, the CFPB announced that it is postponing certain industry data collection deadlines. Specifically, the Bureau will not expect quarterly information reporting by certain mortgage lenders under the Home Mortgage Disclosure Act (“HMDA”) and Regulation C,…

We have been closely following a lawsuit challenging a 2019 Nevada amendment that relates to the treatment of spousal credit history during the credit application process. Senate Bill 311, which went into effect on October 1, 2019, allows an applicant for credit with no credit history to request that the creditor treat the applicant’s credit history as identical to that of the applicant’s spouse during the marriage. The lawsuit, filed the same day the amendment…

How will regulatory agencies like the CFPB, FTC, and State Attorneys General react to the consumer financial impacts of COVD-19?  What kinds of consumer litigation may be spurred by the crisis? On Monday, April 6, 2020, from 12:00 p.m. to 1:00 p.m. ET, Ballard Spahr will hold a webinar, “Consumer Financial Regulatory and Litigation Fallout from the COVID-19 Crisis.”  Our special guest speakers will be Richard Cordray, former Director of the Consumer Financial Protection Bureau…

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) includes the following key provisions that affect financial institutions and regulation of financial institutions: Section 4003 – Emergency Relief and Taxpayer Provisions Section 4003 of the CARES Act generally authorizes the Treasury Secretary to make loans, loan guarantees, and other investments in support of eligible businesses, States, and municipalities that do not, in the aggregate, exceed $500,000,000,000 and provide the subsidy amounts necessary for such…

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) includes the following provisions of particular interest to members of the consumer financial services industry: Credit Reporting.  Section 4021 (Credit Protection During COVID-2019) amends the Fair Credit Reporting Act to impose new COVID-19 related reporting requirements on furnishers of information to consumer reporting agencies.  Under Section 4021, if a furnisher (for example, a financial institution that lends money to consumers) makes an accommodation with respect to…