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On May 4, the Florida Office of Financial Regulation reminded Money Transmitter Part II licensees that the deadline to renew licenses has been extended to June 1, 2020 (previously covered here). Licensees that fail to renew by June 1 will be considered inactive and will need to pay an additional fee to reactivate the license. Inactive licenses not renewed by July 30, 2020 will expire.
On April 17, the commissioner of the Florida Office of Financial Regulation issued Emergency Order 2020-03, which temporarily expands the motor vehicle retail installment initial pay rule. The order permits a motor vehicle retail installment seller licensed under Chapter 520 of the Florida Statues to allow the first payment of a motor vehicle retail installment contract to be scheduled up to 90 days from the date of the loan.
Florida Office of Financial Regulation issues guidance regarding steps taken to keep staff and stakeholders safe
In April, the Florida Office of Financial Regulation (OFR) provided information regarding its staff and stakeholders. The guidance provides that OFR is closed to the public and staff are teleworking. Further, registration staff are continuing to process registration applications and examination staff are conducting streamlined, remote examinations using phone and email correspondence.
Florida issues executive order suspending the assessment and collection of taxation for notes and obligations under the CARES Act
On April 6, the Florida governor issued an executive order suspending the assessment and collection of excise taxes on documents imposed pursuant to Chapter 201 of the Florida statutes for all notes and other written obligations made pursuant to Title I of the CARES Act (the Paycheck Protection Program). The Department of Revenue is directed to issue an emergency order establishing that taxation imposed under Chapter 201 on such notes and obligations is not owed as a result of the suspension.
Florida Office of Financial Regulation encourages small businesses to take advantage of CARES relief
On April 2, the Florida Office of Financial Regulation promoted the economic relief available for small businesses in the federal CARES Act signed into law by President Trump on March 27. The Florida Chief Financial Officer Jimmy Patronis and OFR Commissioner Russell Weigel, III were both quoted in support of the bill and encouraged small businesses to take advantage of the relief offered.
On April 2, the Florida governor issued an executive order suspending and tolling any statute providing for (i) a mortgage foreclosure cause of action under Florida law for 45 days and (ii) an eviction cause of action under Florida law solely as it relates to non-payment of rent by residential tenants due to the Covid-19 emergency for 45 days.
On April 1, the governor of Florida issued an executive order requiring all senior citizens and individuals with a significant underlying medical condition to stay at home. The order also requires all persons in Florida to remain at home unless necessary to obtain or provide essential services or conduct essential activities. The order refers to the U.S. Department of Homeland Security’s Essential Critical Infrastructure Workforce for inclusion of “essential services.” This list includes financial services institutions and their workers.
On March 27, Florida’s secretary of state issued an emergency order postponing the annual report filing deadlines for businesses. The order extends reporting deadlines to June 30, unless an additional extension is granted through a subsequent order.
Florida Office of Financial Regulation issues emergency order to extend financial statement deadlines
On March 26, the Commissioner of the Office of Financial Regulation issued an emergency order extending the filing deadlines for annual financial condition reports, financial statement filings, first quarter Call Reports or financial reports or first quarter capital equivalency, and asset maintenance reports for a period of 45 days unless extended by order. The guidance further provides that deadlines for internal audit completion and related reporting deadlines as well as annual and special meetings are suspended and tolled for a period of 45 days unless extended by order.