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On August 12, the FDIC issued FIL-39-2022 to provide regulatory relief to financial institutions and help facilitate recovery in areas of Missouri affected by severe storms and flooding from July 25-28. The FDIC acknowledged the unusual circumstances faced by institutions affected by the storms and suggested that institutions work with impacted borrowers to, among other things: (i) extend repayment terms; (ii) restructure existing loans; or (iii) ease terms for new loans to those affected by the severe weather, provided the measures are done “in a manner consistent with sound banking practices.” Additionally, the FDIC noted that institutions “may receive favorable Community Reinvestment Act consideration for community development loans, investments, and services in support of disaster recovery.” The FDIC will also consider regulatory relief from certain filing and publishing requirements.
On January 12, HUD announced disaster assistance for certain areas in Missouri impacted by severe storms, straight-line winds, and tornadoes in December 2021. The disaster assistance supplements state, tribal, and local recovery efforts in specific counties, and provides foreclosure relief and other assistance to affected homeowners following President Biden’s major disaster declaration on January 11. According to the announcement, HUD is providing an automatic 90-day moratorium on foreclosures of FHA-insured home mortgages for covered properties and is making FHA insurance available to victims whose homes were destroyed or severely damaged, such that “reconstruction or replacement is necessary.” HUD’s Section 203(k) loan program allows individuals who have lost homes to finance the purchase of a house or refinance an existing house along with the costs of repair, through a single mortgage. The program also allows homeowners with damaged property to finance the rehabilitation of existing single-family homes. HUD also announced it is allowing applications for administrative flexibility waivers for Community Planning and Development Grantees and public housing authorities. Recently, HUD announced it will provide the same foreclosure relief and assistance to Alabama, Arkansas, Kansas, and Washington state homeowners affected by severe storms, flooding, tornados, and wildfires in those states. (See press releases here, here, here, and here).
On June 11, the Missouri governor issued an executive order extending, among others, Executive Order 20-08 relating to remote notary services, which was previously covered here. The extension permits notarial acts to be performed using audio-video technology, provided certain conditions are met, through August 28.
On May 4, the Missouri governor issued Executive Order 20-10, which extends Executive Orders 20-04 (authorizing specific departments to waive or suspend statutory requirements and administrative rules), 20-05 (relating to the restaurant industry), 20-06 (relating to organized militia), and 20-08 (relating to remote notarization), issued in response to Covid-19. Executive Order 20-04 was previously covered here and Executive Order 20-08 was previously covered here.
On April 16, the Missouri Department of Health extended the duration of a prior “Stay Home Missouri” order to May 3, 2020, unless extended or modified. Relying on the Cybersecurity and Infrastructure Security Agency (CISA) advisory memorandum, financial services are considered essential.
On April 10, Missouri’s secretary of state announced three approved electronic notary service providers, noting that additional vendors are expected to be approved at a later time. The announcement came in light of the state’s shift to remote practices in response to the Covid-19 crisis.
On April 6, the Missouri governor issued Executive Order 20-08 authorizing notarial acts to be performed utilizing audio-video technology, provided certain conditions are met. The order terminates on May 15, 2020 unless extended.
On March 18, Missouri’s governor issued Executive Order 20-04, which provides certain departments, including the Department of Commerce and Insurance and the Division of Professional Regulation and its boards, with authority to temporarily waive or suspend the operation of any statutory requirement or administrative rule, upon approval of the Office of the Governor, where strict compliance with such requirements and rules would prevent, hinder, or delay necessary action by the department to respond to Covid-19. In line with the executive order, the Department of Commerce and Insurance issued guidance to all insurers conducting the business of insurance in Missouri regarding assistance to policy holders impacted by Covid-19.
On March 17, the Missouri Division of Finance communicated with state-chartered banks, requesting that the MDF be notified of any changes affecting schedules or services offered. If the closure of an entire facility for more than 24 hours is necessary, banks are instructed to ensure that the community has alternative means to access banking services.
- Jedd R. Bellman to provide an “Attorney exemption/medical debt update” at the North American Collection Agency Regulatory Association annual conference
- Kathryn L. Ryan to discuss “What should crypto regulation look like: Legislation, regulation and consumer issues” at WCL's First Annual Virtual Currency Law Institute
- Elizabeth E. McGinn to discuss “How to mitigate and manage third-party risks: Leveraging tools and best practices” at The Knowledge Group’s webcast
- Elizabeth E. McGinn, Benjamin W. Hutten, and James C. Chou to discuss “The evolving regulatory landscape: Third-party and cyber risk management” at the 2022 mWISE Conference
- Jeffrey P. Naimon to discuss “Truth in lending” at ABA’s Consumer Financial Services Basics 2022 virtual conference
- Sherry-Maria Safchuk to discuss “For your eyes only: Privacy updates for 2022-2023” at CCFL’s Annual Consumer Financial Services Conference
- James T. Parkinson to present a “Global anti-corruption update” at IBA’s annual conference