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District of Columbia Department of Insurance, Securities and Banking issues bulletin regarding submission of filings
On April 24, the District of Columbia Department of Insurance, Securities and Banking issued a Bulletin 0X-SB-00X 03/20 suspending the procedures established by Bulletin 03-SB-04-03/21 in light of the Covid-19 public health emergency. Required filings and fee payments that would have been submitted pursuant to the procedures outlined in Bulletin 03-SB-04-03/21 must now be submitted to the department via PDF to a specified email address. Further, instead of physical checks, the associated payments must be submitted in electronic form in accordance with the instructions in the bulletin.
District of Columbia Department of Insurance, Securities and Banking issues bulletin to certain insurance companies
On April 23, the District of Columbia Department of Insurance, Securities and Banking issued a bulletin to insurers, captives, and risk retention groups regarding modified regulatory filing requirements during the public health emergency. While companies are still required to make all required electronic filings with the NAIC based on modified filing deadlines, if applicable, the department will allow insurers an additional 30 to 60 days, depending on the filing, to complete filings upon a request to the department on or before the normal deadline. The bulletin sets forth the filings eligible for 30- or 60-day extensions. The bulletin also provides guidance regarding electronic filings and signatures. Further, while the department will not conduct any on-site examination work during the stay-at-home order, the department may still request certain electronic records to track trends arising from the Covid-19 pandemic.
The District of Columbia has enacted the Covid-19 Response Supplemental Emergency Amendment Act of 2020. Under the Act, among other things, for the duration of the public health emergency and 60 days after its conclusion, debt collectors are prohibited from, among other things: (i) initiating, filing, or threatening a new collection lawsuit, garnishment, seizure, attachment, or repossession; or (ii) initiating any communication with debtors via written or electronic communication, such as text, email, or telephone, subject to certain exceptions.
District of Columbia permits mortgage brokers and originators to work from home, delays reporting deadlines
On March 27, the District of Columbia Department of Insurance, Securities and Banking issued guidance to mortgage lenders, mortgage brokers and mortgage loan originators permitting them to work from non-licensed branches or locations during the Covid-19 outbreak. The guidance requires the maintenance of appropriate data protection and cybersecurity measures when working remotely. The department also extended the deadline for filing annual reports from March 31 to June 1. Finally, the guidance notes that all evictions of tenants and foreclosed homeowners on or before May 1 are stayed, and required mediation hearings are extended from 90 days to 120 days following the date of mailing of the notice of default.
On March 15, the District of Columbia Superior Court issued a memorandum staying all evictions, including those involving foreclosed homeowners, until May 1, 2020.
- Jonice Gray Tucker to discuss “How the new administration sets the tone for 2021” at the American Conference Institute Legal, Regulatory and Compliance Forum on Fintech & Emerging Payment Systems
- Sherry-Maria Safchuk to discuss UDAAP in consumer finance at an American Bar Association webinar
- Jeffrey P. Naimon to discuss "What to expect: The new administration and regulatory changes" at the Mortgage Bankers Association Legal Issues and Regulatory Compliance Conference
- Jonice Gray Tucker to discuss “The future of fair lending” at the Mortgage Bankers Association Legal Issues and Regulatory Compliance Conference
- Steven R. vonBerg to discuss "LO comp challenges" at the Mortgage Bankers Association Legal Issues and Regulatory Compliance Conference
- Michelle L. Rogers to discuss "Major litigation" at the Mortgage Bankers Association Legal Issues and Regulatory Compliance Conference
- Michelle L. Rogers to discuss “The False Claims Act today” at the Federal Bar Association Qui Tam Section Roundtable