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Financial Services Law Insights and Observations

Connecticut regulator urges institutions not to use CARES Act checks to satisfy debt

State Issues Covid-19 Connecticut Debt Collection Consumer Finance Overdraft Bank Compliance

State Issues

On April 16, the Connecticut Department of Banking issued a letter to all Connecticut financial institutions, “strongly” urging them not to use stimulus payments to satisfy overdrafts and not to exercise any right of offset against other debts for 30 days after the payment is received without express consumer consent. If an institution’s systems automatically use the payment to satisfy an overdraft, the department urged reversing the transaction as soon as possible.