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Financial Services Law Insights and Observations

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  • Connecticut Department of Banking issues guidance to state chartered banks and credit unions

    State Issues

    On March 17, the Connecticut Department of Banking issued guidance to Connecticut state chartered banks and credit unions on Covid-19-related issues. The guidance encourages financial institutions to work with all borrowers whose ability to make loan repayments may be impacted by Covid-19. Such efforts may include easing credit terms for new loans, waiving overdraft fees, increasing the number of allowed money market withdrawals, waiving CD early withdrawal penalties, waiving late fees for loan balances, and offering payment accommodations. The guidance notes that any modifications to existing loans deemed prudent by financial institutions in light of the circumstances will not be subject to regulatory criticism. The guidance also requests that financial institutions inform their servicers and collection agencies regarding the servicers’ policies so that borrowers receive information about possible accommodations.

    State Issues Covid-19 Connecticut

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  • Connecticut Department of Banking issues guidance to residential mortgage servicers

    State Issues

    On March 18, the Connecticut Department of Banking issued guidance to residential mortgage servicers on Covid-19-related issues. The Department encourages mortgage servicers to work with all borrowers whose ability to make loan repayments may be impacted by Covid-19. Such efforts may include waiving late fees, offering forbearance plans or other deferment options, and having adequate staff available to proactively work with borrowers. Mortgage servicers should also inform their internal and external collection teams regarding the servicers’ policies so that borrowers receive information about possible accommodations. The guidance also notes that Connecticut is extending Small Business Express loans for 90 days, offering a 90-day grace period on making payments, and delaying payment of some business taxes for 60 to 90 days.

    State Issues Covid-19 Connecticut Mortgages

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  • Connecticut issues stay at home order

    State Issues

    On March 20, the Connecticut Governor issued a stay at home order. The order requires non-essential businesses or not-for-profit entities to reduce their in-person workforces at any workplace locations by 100%. Essential businesses include banks, insurance companies, check cashing services, and other financial institutions. The order is effective from 8:00 PM on March 23, 2020, through April 22, 2020, unless earlier modified, extended, or terminated by the Governor. On March 22, the Connecticut Governor issued a subsequent executive order that clarifies the scope of the original home order. Additional guidance regarding business exemptions under the executive orders has also been released.

    State Issues Covid-19 Connecticut

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  • Connecticut issues order on remote notarization

    State Issues

    On March 23, the Connecticut Governor issued an order to permit any notarial act required under Connecticut law to be performed using an electronic device or process that allows a notary public commissioned in accordance with state law and a remotely located individual to communicate with each other simultaneously by sight and sound, provided that certain conditions set forth in the order are met. This change is effective immediately through June 23, 2020.

    State Issues Covid-19 Connecticut Notary

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  • Connecticut Dept. of Banking issues work from home guidance

    State Issues

    On March 9, the Connecticut Department of Banking issued a memorandum indicating that individuals who work for Consumer Credit Licensees currently licensed in Connecticut may temporarily work from home even though such home location is not currently licensed by as a branch office, so long as certain criteria are met.

    State Issues Licensing Covid-19 Connecticut

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