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Financial Services Law Insights and Observations

Michigan regulator encourages financial institutions to avoid offsetting CARES Act stimulus payments

State Issues Covid-19 Michigan CARES Act Bank Compliance ATM Overdraft

State Issues

On May 14, the Michigan Department of Insurance and Financial Services issued a bulletin “strongly” urging Michigan financial institutions not to access CARES Act stimulus payments to satisfy overdrafts or to exercise any right of offset against the funds without the agreement of the customer or member. The regulator also “strongly” urged financial institutions not to use CARES Act stimulus payments for ATM, late payment, overdraft, or other fees.