Subscribe to our InfoBytes Blog weekly newsletter and other publications for news affecting the financial services industry.
On August 21, the Connecticut governor issued Executive Order No. 7000, which, among other things, extends the eviction moratorium set forth in previous executive orders, subject to certain modifications (previously discussed here). Pursuant to the modifications, a landlord of a dwelling unit is prohibited from delivering a notice to quit or serve or return a summary process action until October 1, 2020, subject to certain exceptions.
On August 21, the Connecticut Department of Banking issued a memorandum extending through December 31, 2020, its no-action position (previously discussed here and here) with respect to various licensees temporarily working from home during Covid-19, provided that certain criteria set forth in the memorandum are met.
On July 13, the Connecticut governor issued Executive Order No. 7GGG, which authorizes the Connecticut Department of Housing to create a temporary rental housing assistance program for tenants who meet criteria established by the department. The order also authorizes the Connecticut Housing Finance Authority to create a temporary mortgage assistance program for borrowers who meet certain criteria to be established by the department to mitigate the effects of the Covid-19 pandemic.
On June 19, the banking commissioner in Connecticut issued a memorandum extending its “no action” position regarding temporary work-from-home guidance. Previously covered here and here, the memorandum permits consumer credit licensees to work from home, even though such home location is not licensed by the Banking Department, so long as certain criteria spelled out in the memorandum are met. The guidance is extended through August 31, 2020.
On May 20, the Connecticut Department of Banking issued a memorandum extending its no-action position (previously discussed, here) with respect to licensees temporarily working from home during Covid-19 through June 30, 2020, provided that certain criteria set forth in the memorandum are met.
On April 29, the Connecticut Department of Insurance issued a bulletin to foreign-chartered insurers, health care centers, and fraternal benefit societies authorized to do business in Connecticut discussing regulatory relief in light of the Covid-19 pandemic. The department continues to require that foreign companies timely make all required electronic filings. However, upon request, it will grant an additional 30 or 45 days to complete many hard copy filings, a list of which is included in the bulletin.
On April 29, the Connecticut Department of Insurance issued a bulletin to state-chartered insurers, health care centers and fraternal benefit societies discussing regulatory relief in light of the Covid-19 pandemic. The department continues to require that domestic companies timely make all required electronic filings. However, upon request, it will grant an additional 30, 45, 60 or 90 days (depending upon the type of filing) to complete many hard copy filings. A list of these filings is included in the bulletin.
On April 23 and 21, nine states announced a multi-state initiative to provide student loan relief options for borrowers with privately held student loans not covered by the CARES Act. California, Colorado, Connecticut, Illinois, Massachusetts, New Jersey, Vermont, and Washington outlined within their announcements specific measures for borrowers with commercially-owned Federal Family Education Loan Program loans and borrowers with private student loans who are struggling to make payments due to the Covid-19 pandemic. The announcements also noted that Virginia is participating in the initiative as well. These relief options, offered in conjunction with the listed private student loan servicers, include (i) a minimum 90-days of forbearance relief; (ii) a waiver of late fees; (iii) no negative credit reporting; (iv) a 90-day moratorium on collection lawsuits; and (v) enrollment in applicable borrower assistance programs, such as income-based repayment. The states cautioned that enrollment in these relief options is not automatic, and recommended borrowers contact their student loan servicer to see what options best suit their needs.
In addition, California, Colorado, Connecticut, New Jersey, Vermont, and Washington recommended that regulated student loan servicers with limited ability to take these actions due to investor restrictions or contractual obligations “should instead proactively work with loan holders whenever possible to relax those restrictions or obligations.”
On April 16, the Connecticut Department of Banking issued a letter to all Connecticut financial institutions, “strongly” urging them not to use stimulus payments to satisfy overdrafts and not to exercise any right of offset against other debts for 30 days after the payment is received without express consumer consent. If an institution’s systems automatically use the payment to satisfy an overdraft, the department urged reversing the transaction as soon as possible.
On April 10, the Connecticut governor issued an executive order that, among other things, provides protections for residential renters impacted by Covid-19. For example, renters are provided an automatic 60-day grace period for April rent and, upon request, a 60-day grace period for May rent. In addition, no landlord, or landlord’s representative may deliver notice to evict except in the case of serious nuisance.
- Steven R. vonBerg to discuss "Non-QM market overview & the impact of QM 2.0" at the IMN Non-QM Virtual Conference
- Buckley Webcast: Looking ahead — Tighter scrutiny of deposit and payment practices
- Jeffrey P. Naimon to discuss "What have you bought non-QM post-Covid?" at the IMN Non-QM Virtual Conference
- Garylene D. Javier to moderate "Innovation in an evolving privacy landscape" at the American Bar Association Business Law Section Consumer Financial Services Committee Winter Meeting