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On December 22, 2020, the Rhode Island Department of Business Regulation extended interim guidance permitting mortgage loan originators, lenders, loan brokers, and exempt company registrants to work from home, even if the home is not a “licensed branch” or located outside of Rhode Island (previously covered here, here, and here.) To take advantage of this exemption, the individual must maintain certain specified data security provisions. This extension is set to expire March 31, 2021.
Rhode Island Division of Banking issues guidance on workplace practices to mitigate spread of Covid-19
On November 6, the Rhode Island Department of Business Regulation, Division of Banking issued Banking Bulletin 2020-6 announcing certain standards for personnel and office operations that it encourages financial institutions to implement to mitigate further spread of Covid-19. These standards include, among others, guidelines for employee mask-wearing and congregation, and arrangement of office furniture to encourage social distancing.
On September 28, the Rhode Island Department of Business Regulation, Banking Division, extended previous guidance (previously covered here and here) issued to mortgage loan originators, lenders, loan brokers, and exempt company registrants. The guidance permits working from home, even if the home is located outside of Rhode Island or is not a licensed branch, so long as specified data security provisions are met. The department extended this guidance until December 31, 2020.
On May 20, State of Rhode Island District Court issued Administrative Order 2020-02, announcing that it would recommence adjudicating eviction matters on June 2, and detailing a set of temporary practices and protocols for eviction matters. Similarly, on May 19, the State of Rhode Island Department of Business Regulation issued Certified Constables Bulletin 2020-1.2, noting that certified constables should conduct service of process and executions regarding eviction at a time and in a manner specified by the court.
On May 6, the governor of Rhode Island extended multiple executive orders related to the Covid-19 pandemic until June 5, 2020. These include, among others, orders related to quarantines, remote corporate and shareholder meetings, and unemployment insurance.
On April 28, the attorney general of Rhode Island issued guidance to financial institutions, credit unions, creditors and debt collectors announcing that, in the attorney general’s view, all CARES Act recovery rebates are exempt from attachment and execution under Rhode Island law. The attorney general also warned that if a creditor attempts to attach a CARES Act recovery rebate, the attorney general’s office may bring a civil action or seek injunctive relief.
On April 28, the Rhode Island Department of Business Regulation, Banking Division, amended previous guidance (previously covered here) issued to mortgage loan originators, lenders, loan brokers and exempt company registrants. The previous guidance permitted working at home, even if the home is located outside of Rhode Island or is not a licensed branch. The department extended this guidance until June 30, 2020.
Rhode Island clarifies timing requirements for foreclosure mediation notices with CARES Act forbearances
On April 15, Rhode Island’s Superintendent of Banking issued a bulletin to clarify how mortgagors should implement CARES Act forbearances to accord with the state’s foreclosure mediation statute, which requires certain notices be mailed within 120 days of default. During the pendency of the Covid-19 pandemic, mortgagors must mail the required notice within 120 days after the termination of the forbearance agreement, subject to certain conditions.
On April 10, Rhode Island Governor Gina Raimondo issued an executive order mandating that all shareholder annual and special meetings must be held remotely due to the Covid-19 crisis. The order will remain in effect until May 8, unless renewed, modified, or rescinded.
On April 3, the Rhode Island Department of Business Regulation Banking Division issued a bulletin asking premium finance companies to work with insured individuals and entities to maintain coverage during the Covid-19 crisis. The bulletin requests that premium lenders: (1) extend payment periods, implement alternative payment plans, and take other necessary steps to avoid the cancellation or lapse of coverage during the emergency period; (2) implement alternative payment methods, such as facilitation electronic payments; (3) consider waiving late payments and other penalties, and extend grace periods on statement due dates and; (4) streamline processes that might delay issuing new coverage or cause the lapse of existing coverage.
- Jonice Gray Tucker to moderate “Pandemic relief response and lasting impacts on access, credit, banking, and equality” at the American Bar Association Business Law Section Spring Meeting
- Jeffrey P. Naimon to discuss "Post-pandemic CFPB exam preparation" at the Mortgage Bankers Association Spring Conference & Expo
- Jonice Gray Tucker to discuss "Making fair lending work for you" at the Mortgage Bankers Association Spring Conference & Expo
- Jonice Gray Tucker to discuss "Reading the tea leaves of President Biden’s initial financial appointees" at LendIt Fintech
- Moorari K. Shah to discuss “CA, NY, federal licensing and disclosure” at the Equipment Leasing & Finance Association Legal Forum
- Jonice Gray Tucker to discuss "Compliance under Biden" at the WSJ Risk & Compliance Forum
- Sherry-Maria Safchuk to discuss UDAAP at an American Bar Association webinar
- Jonice Gray Tucker to discuss “The future of fair lending” at the Mortgage Bankers Association Legal Issues and Regulatory Compliance Conference