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Louisiana regulator provides guidance on business continuity plans
On April 1, the Louisiana Office of Financial Institutions issued a bulletin urging financial institutions to review their disaster recovery/business continuity plans and update them as needed to ensure that all interdependent operations are considered. The guidance includes a list of considerations, including, among other things: supplying staff with protective equipment and training; updated contact information for third party services and consideration of third party services that might become impaired in an incident; contingency communication process; remote work possibilities; identification of critical operations, including as examples, core processing systems, ATM processing and replenishment, online banking systems, payment processing, and wire processing; cross-training for continuity; and liquidity and cash considerations.
Rhode Island regulator delays reporting deadlines
In light of widespread interruptions created by the Covid-19 emergency, the Rhode Island Division of Banking extended the due date for debt collectors, small loan lenders, and debt management companies to submit 2020 Rhode Island Annual Reports to April 30, 2020. Extensions beyond that date will be considered on a case-by-case basis.
Illinois Department of Financial and Professional Regulation issues notice to consumer credit licensees
On March 30, the Illinois Department of Financial and Professional Regulation (Department) issued a notice to consumer credit licensees stating that it appreciates advance notice of any changes to the licensee’s usual business practices. Licensees are expected to “act responsively and proactively to address any consumer harm that may arise,” including through waiving defaults where a consumer is unable to make a payment as a result of the licensee’s business practices. New credit transactions originated during Covid-19 will be evaluated as part of the next examination cycle.
Illinois Department of Financial and Professional Regulation issues guidance to credit unions
On March 30, the Illinois Department of Financial and Professional Regulation (Department) issued a notice to credit unions providing that credit unions may submit a request to postpone the credit union’s 2020 annual meeting to the Department’s Credit Union Section. In addition, the guidance requires credit unions to submit a waiver request to hold annual membership meetings in a month other than January, February, and March.
Illinois Department of Financial and Professional Regulation issues questions and answers to credit unions regarding Covid-19
On March 30, the Illinois Department of Financial and Professional Regulation (Department) issued questions and answers to credit unions related to Covid-19 safety concerns. The guidance provides responses to questions regarding, among other things, receiving extensions for annual meetings, holding annual meetings by teleconference or other communications equipment, whether prior approval from the Department is required to close branches or lobbies, and whether the Department needs to approve any concessions, such as payroll interruption loans, extension, or deferments.
Illinois Department of Financial and Professional Regulation issues notice to currency exchange and money transmitter licensees
On March 30, the Illinois Department of Financial and Professional Regulation (Department) issued a notice encouraging currency exchange and money transmitter licensees to provide the Department with advance notice of any changes to their usual business practices. The Department expects all licensees to act responsibly and proactively to address any consumer harm that may arise.
Texas Department of Banking issues business continuity planning recommendations
On March 30, the Texas Department of Banking, in conjunction with the Independent Bankers Association of Texas and the Texas Bankers Association, issued a set of recommendations for banks to consider as they develop business continuity plans during the Covid-19 crisis. The guidance specifically notes that the recommendations do not constitute required action.
Illinois Department of Financial and Professional Regulation issues notice to title insurance licensees and registered agents
On March 30, the Illinois Department of Financial and Professional Regulation (Department) issued a notice encouraging title insurance licensees and registered agents to provide the Department with advance notice of any changes to their usual business practices. If a registered agent application has been submitted, it will be processed as quickly as possible.
Nebraska publishes depository office closure form
On its website, the Nebraska Department of Banking and Finance (Department) published a Request for Proclamation to Authorize Office Closure form. If a financial institution decides to close any or all of its offices for an emergency, it must notify the Department. If the closure will last longer than 48 hours, the financial institution must receive Department approval. Financial institutions are instructed to submit the form to the Department via e-mail to the institution’s review examiner, and the Department will respond as soon as possible.
Minnesota Commerce Department offers relief to franchise registrants
On March 30, pursuant to a Commissioner Order issued on the same day, the Minnesota Commerce Department issued Regulatory Guidance 20-10 to franchise registrants. The guidance extends the deadline for franchisors to file annual reports that were due by April 30, pursuant to Minn. Stat. § 80C.08, subd. 1, to June 30. Franchisors are encouraged to submit annual reports through the department’s online e-File system.