Financial Services Perspectives

Regulatory, compliance, and litigation developments in the financial services industry

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Financial Services Perspectives

CFPB Offers Flexibility for Responding to Credit Reporting Disputes During COVID-19 Pandemic — But Private Litigants May Not

By R. Aaron Chastain, Jonathan R. Kolodziej & Grant A. Premo

April 3, 2020

The CFPB’s April 1, 2020, statement regarding credit reporting for loans affected by COVID-19 announced a “flexible supervisory and enforcement approach during this pandemic.” In addition to guidance regarding furnishing obligations while consumers are impacted by COVID-19, the bureau specifically announced relaxed enforcement standards for companies struggling to respond to consumer credit disputes within the statutory timelines due to the challenging conditions created by the COVID-19 pandemic. This is certainly good news for furnishers of…

Financial Services Perspectives

Credit Reporting Requirements and COVID-19 – CFPB and FHA Weigh In

By R. Aaron Chastain, Jonathan R. Kolodziej & Grant A. Premo

April 3, 2020

We’ve been tracking regulatory developments related to credit reporting for loans where borrowers have been affected by the coronavirus outbreak. On April 1, the CFPB issued a statement about credit reporting for loans affected by COVID-19. The statement announces the CFPB’s “flexible supervisory and enforcement approach during this pandemic” and seeks to reassure credit reporting agencies and furnishers that the “circumstances [they] face as a result of the COVID-19 pandemic and entities’ good faith efforts…

Financial Services Perspectives

Mortgage Servicers: Keep an Eye on the CFPB’s Advice to Borrowers Impacted by COVID-19

By Jonathan R. Kolodziej & Jason R. Bushby

April 2, 2020

On March 31, 2020, the CFPB posted a “Guide to coronavirus mortgage relief options,” which provides instruction to mortgage loan borrowers who may be impacted by COVID-19 on when and how to go about obtaining assistance. While we have previously discussed compliance challenges that are likely to arise related to verbal loss mitigation applications and the obligations surrounding short-term forbearance and repayment plans, the CFPB’s borrower guide adds some additional considerations that…

Financial Services Perspectives

Federal Reserve Implements Aggressive Liquidity Campaign as Growing Corporate Debt Threatens to Exacerbate COVID-19 Economic Toll

By Edward S. Sledge IV, Benjamin William Perry & Brian R. Epling

April 1, 2020

In response to the recent COVID-19 outbreak, Congress recently approved a $2 trillion stimulus package in an attempt to offset the potentially disastrous economic effects of COVID-19. Meanwhile, central banks are implementing increasingly drastic measures aimed at preserving the availability of capital during the looming recession, which appears increasingly imminent as the global economy remains in a standstill. Corporate Debt Balloons to All-Time Highs “It was the best of times, it was the worst of…

Financial Services Perspectives

Federal Reserve Acts to Bolster Auto Finance, Credit Card, Student Lending Industries

By Andrew J. Narod, C. Meade Hartfield, Lee Gilley & J. Riley Key

April 1, 2020

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In an action somewhat lost amidst the unprecedented $2 trillion Coronavirus Aid, Relief, and Economic Security Act (CARES Act), the Federal Reserve’s Board of Governors announced a series of five “extensive new measures” to provide liquidity for certain sectors of the nation’s economy. One of those liquidity facilities, the reintroduced Term Asset-Backed Securities Loan Facility (TALF), promises to provide immediate relief to portions of the consumer financial services industry, including automobile finance, credit cards, and…

Financial Services Perspectives

Coronavirus Economic Stabilization Act of 2020: Implications for Consumer Financial Services

By Christy W. Hancock, Michael Gordon, J. David Stewart III, Lee Gilley, Alex McFall & Brian R. Epling

March 31, 2020

On Friday, President Trump signed the Coronavirus Economic Stabilization Act of 2020 (CARES Act). The significant legislation directs more than $2 trillion into fighting the COVID-19 pandemic and stimulating America’s economy for the duration of the pandemic. This blog summarizes some of the provisions that are most relevant to financial institutions that make or service consumer loans. Credit Reporting The CARES Act amends the Fair Credit Reporting Act (FCRA) to include a section specifically addressing…

Financial Services Perspectives

Congress’ Third Major Coronavirus Legislation Makes Bankruptcy Relief for Potential and Current Individual Debtors Easier

By Glenn E. Glover & James Bailey

March 30, 2020

On Friday March 27, 2020, President Trump signed into law the third major piece of coronavirus-related legislation in the last several weeks – the Coronavirus Aid, Relief, and Economic Security Act (CARES). The new law contains several amendments to the Bankruptcy Code. One of these amendments increases the maximum indebtedness for a “small business debtor” to $7.5 million and is discussed in a recent Bradley email alert. The other amendments are discussed herein. New…

Financial Services Perspectives

CFPB Eases Reporting Requirements

By Michael Gordon & Brian R. Epling

March 30, 2020

On March 26, the CFPB announced an easing of certain reporting requirements in order to allow financial services companies to focus on responding to consumers during the COVID-19 pandemic. The CFPB postponed several different reporting requirements relating to the Home Mortgage Disclosure Act (HMDA), credit cards, and prepaid accounts. In an unusual step for the bureau, the CFPB issued a policy stating that it “does not intend to cite in an examination or initiate an…

Financial Services Perspectives

Federal Regulatory Agencies Offer Interagency Statement Regarding COVID-19-Related Loan Modifications and Status Reporting

By R. Aaron Chastain & Michael Gordon

March 26, 2020

The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, the Consumer Financial Protection Bureau, and the Conference of State Bank Supervisors issued an Interagency Statement on March 22 urging regulated financial institutions to work with borrowers affected by COVID-19. The statement “encourages financial institutions to work prudently with borrowers who are or may be unable to meet…

Financial Services Perspectives

Fannie Mae and Freddie Mac Announce Relief Plan for Multifamily Borrowers

By Alex McFall, Brian R. Epling & Benjamin William Perry

March 26, 2020

On Tuesday, Fannie Mae and Freddie Mac, in coordination with the Federal Housing Finance Agency, announced relief plans to discourage multifamily landlords from evicting renters from properties as a result of non-payment. In exchange, Fannie Mae and Freddie Mac are allowing multifamily landlords (whose loans are financed by Freddie or Fannie) to defer loan payments up to 90 days due to hardship related to COVID-19. According to Freddie Mac’s press release, it expects that…

Financial Services Perspectives

Regulatory, compliance, and litigation developments in the financial services industry

Blog Authors

CFPB Offers Flexibility for Responding to Credit Reporting Disputes During COVID-19 Pandemic — But Private Litigants May Not

Credit Reporting Requirements and COVID-19 – CFPB and FHA Weigh In

Mortgage Servicers: Keep an Eye on the CFPB’s Advice to Borrowers Impacted by COVID-19

Federal Reserve Implements Aggressive Liquidity Campaign as Growing Corporate Debt Threatens to Exacerbate COVID-19 Economic Toll

Federal Reserve Acts to Bolster Auto Finance, Credit Card, Student Lending Industries

Coronavirus Economic Stabilization Act of 2020: Implications for Consumer Financial Services

Congress’ Third Major Coronavirus Legislation Makes Bankruptcy Relief for Potential and Current Individual Debtors Easier

CFPB Eases Reporting Requirements

Federal Regulatory Agencies Offer Interagency Statement Regarding COVID-19-Related Loan Modifications and Status Reporting

Fannie Mae and Freddie Mac Announce Relief Plan for Multifamily Borrowers

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