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On March 24, The Kentucky Department of Financial Institutions (DFI) provided guidance to non-depository institutions to take steps to comply with CDC directives and Governor Andy Beshear’s guidance and executive orders. Entities are ordered to reduce face-to-face transactions; work with customers affected by the coronavirus to meet their financial needs; implement policies and procedures to work constructively with customers (including by restructuring existing loans, extending repayment terms, and waiving fees); manage COVID-19 related staffing issues; and ensure that business continuity plans include pandemic planning.
On March 23, the Rhode Island Division of Banking issued a bulletin encouraging state-chartered banks and credit unions to take steps to meet the financial services needs of customers and communities impacted by Covid-19. This includes providing alternative service options in light of facility closures, waiving certain fees, increasing ATM cash withdrawal limits, easing restrictions on cashing checks, increasing credit card limits, and offering payment accommodations to borrowers. The Division emphasized that prudent efforts to modify the terms of an existing loan for affected customers will not be subject to regulatory criticism. Finally, the Division noted that it is willing to provide supervisory and regulatory relief to affected financial institutions.
On March 23, the Securities and Business Investments Division of the State of Connecticut Department of Banking issued interim guidance permitting investment company filers to make filings and submit payments electronically “for the foreseeable future.” The guidance also notes that the Division will be working remotely, which may cause delays in processing filings.
New Jersey issues Bulletin No. 20-05 to encourage institutions to meet the financial needs of consumers affected by Covid-19
On March 19, the Commissioner of the Department of Banking and Insurance (Department) signed Bulletin No. 20-05 to encourage institutions to meet the financial needs of consumers affected by Covid-19. The Department also reminded institutions to provide prompt notice to the Department regarding changes to operating hours of branch locations. The Department also requested all notices, inquiries, correspondence, and applications be submitted electronically by e-mail to the appropriate contacts.
On March 19, the Commissioner of the Department of Banking and Insurance (Department) signed Bulletin No. 20-04 encouraging regulated entities and individuals to take the following actions, consistent with safe and sound banking practices: (i) relaxing due dates for loan payments (of all types, including mortgage, commercial, student, and other consumer loans); (ii) extending grace periods; (iii) modifying terms on existing loans; (iv) easing credit card limits; (v) extending new credit; (vi) waiving late fees and other fees; (vii) allowing customers to defer or skip payments; and (viii) delaying the submission of delinquency notices to credit bureaus.
On March 19, the Commissioner of the Department of Banking and Insurance (Department) signed Bulletin No. 20-06 setting forth the Department’s no-action position regarding licensure for certain branch office locations due to individuals temporarily working from home as a result of Covid-19. Licensees must submit a list of all individuals working from home, a certification that the individuals are working from home due to Covid-19, and a certification that the locations will maintain certain data security and privacy protections. The no-action position is effective through April 30. In addition, the Department requested prompt notice for any changes to the operating hours of branch locations.
On March 19, the Massachusetts Division of Banks issued guidance to licensees for temporary closures necessitated by Covid-19. Licensees are encouraged to provide alternative service options to customers when feasible and notify customers about closures and alternatives as soon as practicable. In addition, licensees should notify the Division of any closures, business disruptions or other significant Covid-19-related developments, including significant staff or liquidity shortages or issues with funding closed loans to consumers.
On March 17, the Nebraska Department of Banking and Finance (Department) published a statement for financial institutions working with customers affected by Covid-19 along with regulatory assistance. The statement addresses: (i) establishing emergency branch locations with notice; (ii) clearing back room operations; (iii) moving examinations offsite; (iv) digital applications, audits, and correspondence when working with the Department; (v) using ACH for payments sent to the Department; (vi) delaying credit union annual meetings; and (vii) audit turn around times. The statement also encourages financial institutions to work with affected customers, and provides examples of efforts to be considered by financial institutions. The statement also addresses regulatory reporting requirements and financial condition review, supervisory response, and regulatory relief.
On March 16, the Kansas Office of the State Bank Commissioner (OSBC) announced it would be closed until March 23 with staff working remotely. In addition, all OSBC on-site exams have been suspended at least until the end of March. The OSBC suggested visiting their website (www.osbckansas.org) for additional information regarding temporary bank closures and relocations.
On March 16, the Nebraska Department of Banking and Finance (Department) issued guidance authorizing Nebraska state-chartered credit unions to postpone their annual meetings of members if their meetings are to be held in March, April, May, or June 2020. Board of directors of credit unions are instructed to reschedule the postponed annual meeting so that it is held in July or August 2020 and provide members with 30 days prior written or electronic notice of the rescheduled meeting. Records related to the rescheduling must be kept for the Department’s review.
- Hank Asbill to discuss "The federal fraud sentencing guidelines: It's time to stop the madness" at a New York Criminal Bar Association webinar
- Daniel P Stipano to moderate "Digital identity: The next gen of CIP" at the American Bankers Association/American Bar Association Financial Crimes Enforcement Conference