InfoBytes Blog
Filter
Subscribe to our InfoBytes Blog weekly newsletter and other publications for news affecting the financial services industry.
Connecticut Insurance Department will grant extensions to domestic insurers for hard copy filings
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.
States offer relief to student loan borrowers not covered by CARES Act
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.”
Connecticut regulator urges institutions not to use CARES Act checks to satisfy debt
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.
Connecticut governor issues executive order providing protections to renters
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.
Connecticut regulator: PPP loans exempted from legal lending limit calculations
On April 9, the Connecticut Department of Banking issued guidance to state-chartered credit unions clarifying that they do not need to include loans made as part of the Small Business Administration’s Paycheck Protection Program when calculating limits on member business loans because those loans are fully guaranteed by the U.S. government. The guidance also encouraged credit unions to continue working with members and other financial institutions during the Covid-19 outbreak.
Connecticut governor issues executive order updating remote notarization guidelines
On March 30, Governor Ned Lamont issued updated remote notarization procedures, as part of a broader executive order on public health and safety during the Covid-19 crisis. The update enabled all notarizations to be conducted remotely via simultaneous sight and sound communication technology as long as specific requirements are satisfied. The changes replaced the governor’s previous order and are in place until June 23, unless otherwise noted.
Connecticut regulator permits paperless submission of security and business filings
On March 25, the Securities and Business Investments Division of the State of Connecticut Department of Banking issued interim guidance permitting paperless regulatory filings in light of the Covid-19 pandemic. The interim guidance permits and “highly encourage[s]” securities registration, exemption and covered security filers, as well as business opportunity registration filers, to submit regulatory filings and payments electronically. The Division also waived certain manual signature and notarization requirements.
Connecticut Department of Banking issues guidance to state chartered banks and credit unions
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.
Connecticut Department of Banking issues guidance to residential mortgage servicers
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.
Connecticut issues stay at home order
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.