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  • Texas updates guidance for regulated lenders

    State Issues

    On February 18, the Texas Office of the Consumer Credit Commissioner issued updated guidance (previously covered herehere,  herehere, and here) for regulated lenders relating to the Covid-19 crisis. The guidance: (1) encourages lenders to work with consumers, including by working out modifications to assist with payments, and reviewing policies for fees, late charges, delinquency practices, and repossessions, among other things; (2) reminds lenders of legal requirements for using electronic signatures; and (3) permits lenders to conduct regulated lending activity from unlicensed locations, subject to certain conditions.  The guidance is in effect through March 31, 2021, unless withdrawn or revised.

    State Issues Covid-19 Texas Consumer Credit ESIGN Lending Licensing

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  • Texas Office of Consumer Credit updates advisory to work with consumers

    State Issues

    On February 18, the Texas Office of the Consumer Credit Commissioner updated its advisory bulletin urging credit access businesses to work with consumers during the Covid-19 crisis (previously covered herehereherehere, and here). Among other measures, the regulator urges licensees to increase consumer communication regarding the effects of Covid-19 for licensees, work out modifications for payment difficulties, and review policies for fees, late charges, delinquency practices, and repossessions. The guidance also: (i) reminds licensees of legal requirements for using electronic signatures, and (ii) continues to permit licensees to conduct activity from unlicensed locations, subject to certain conditions. The guidance is in effect through March 31, 2021, unless withdrawn or revised.

    State Issues Covid-19 Texas Consumer Credit Licensing ESIGN

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  • Oklahoma extends working from home guidance

    State Issues

    On December 7, the Oklahoma Department of Consumer Credit extended, for the sixth time, its interim guidance to regulated entities on working from home (see here,  herehereherehere, and here for previous coverage). The guidance sets forth data security standards required for regulated entities with employees working from home and also provides that the department will expedite and waive fees for change of address applications in the event that a licensed location is compromised by Covid-19 or is undergoing decontamination. The guidance was extended through March 31, 2021.

    State Issues Covid-19 Oklahoma Consumer Credit Privacy/Cyber Risk & Data Security

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  • Texas regulators update emergency-related home equity lending guidance

    State Issues

    On November 30, the Texas Department of Banking, Department of Savings and Mortgage Lending, Office of Consumer Credit Commissioner, and Credit Union Department issued updated guidance on emergency measures for home equity lenders to consider in response to the COVID-19 pandemic. The guidance covers emergency measures in relation to the refinance and modification of home equity loans. The guidance also indicates that lenders are permitted to close loans in any area located at the permanent physical address of the lender, attorney, or title company, including outdoor settings such as parking lots.

    State Issues Covid-19 Texas Home Equity Loans Mortgages Consumer Credit

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  • Texas agencies issue revised emergency guidance for home equity lenders

    State Issues

    On November 30, the Texas joint financial regulatory agencies (Department of Banking, Department of Savings and Mortgage Lending, Office of Consumer Credit Commissioner, and Credit Union Department) issued guidance to replace its April 22, 2020 guidance (previously discussed here) regarding emergency measures for home equity lenders to consider in response to the COVID-19 pandemic. The agencies encouraged lenders to work with borrowers to help borrowers recover and provide an opportunity to repay their debt. However, lenders must ensure that they comply with Texas law to have a valid home equity lien. The agencies reiterated guidance regarding authorized closing locations and noted that lenders should consider ways to close loans in accordance with social distancing recommendations.

    State Issues Covid-19 Texas Home Equity Loans Consumer Credit Mortgages

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  • Texas Office of Consumer Credit updates guidance urging property tax lenders to work with borrowers

    State Issues

    On November 16, the Texas Office of the Consumer Credit Commissioner updated its advisory bulletin urging property tax lenders to work with consumers during the Covid-19 crisis (previously discussed herehere, and here) Among other measures, the regulator urges licensees to increase consumer communication regarding the effects of Covid-19 for licensees, work out modifications for payment difficulties, and review policies for fees, late charges, delinquency practices, and repossessions. The guidance also: (i) reminds licensees of legal requirements for using electronic signatures, and (ii) continues to permit licensees to conduct activity from unlicensed locations, subject to certain conditions. The guidance is in effect through December 31, 2020, unless withdrawn or revised.

    State Issues Covid-19 Texas Consumer Credit Licensing Repossession ESIGN

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  • Texas Office of Consumer Credit updates guidance urging credit access businesses to work with borrowers

    State Issues

    On November 16, the Texas Office of the Consumer Credit Commissioner updated its advisory bulletin urging credit access businesses to work with consumers during the Covid-19 crisis (previously covered hereherehere, and here). Among other measures, the regulator urges licensees to increase consumer communication regarding the effects of Covid-19 for licensees, work out modifications for payment difficulties, and review policies for fees, late charges, delinquency practices, and repossessions. The guidance also: (i) reminds licensees of legal requirements for using electronic signatures, and (ii) continues to permit licensees to conduct activity from unlicensed locations, subject to certain conditions. The guidance is in effect through December 31, 2020, unless withdrawn or revised.

    State Issues Covid-19 Texas Consumer Credit Licensing

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  • Texas Office of Consumer Credit updates guidance urging motor vehicle sales finance licensees to work with borrowers

    State Issues

    On November 16, the Texas Office of the Consumer Credit Commissioner updated its advisory bulletin urging motor vehicle sales finance licensees to work with consumers during the Covid-19 crisis (previously covered hereherehereherehere, and here). Among other measures, the regulator urges licensees to increase consumer communication regarding the effects of Covid-19 for licensees, work out modifications for payment difficulties, and review policies for fees, late charges, delinquency practices, and repossessions. The guidance also: (i) reminds licensees of legal requirements for using electronic signatures and (ii) continues to permit licensees to conduct activity from unlicensed locations, subject to certain conditions. The guidance is in effect through December 31, 2020, unless withdrawn or revised.

    State Issues Covid-19 Texas Consumer Credit Auto Finance Licensing

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  • Texas Office of Consumer Credit updates guidance for regulated lenders

    State Issues

    On November 16, the Texas Office of the Consumer Credit Commissioner issued updated guidance (previously covered here,  herehere, and here) for regulated lenders relating to the Covid-19 crisis. The guidance: (1) encourages lenders to work with consumers, including by working out modifications to assist with payments, and reviewing policies for fees, late charges, delinquency practices, and repossessions, among other things; (2) reminds lenders of legal requirements for using electronic signatures; and (3) permits lenders to conduct regulated lending activity from unlicensed locations, subject to certain conditions.  The guidance is in effect through December 31, 2020, unless withdrawn or revised.

    State Issues Covid-19 Texas Consumer Credit

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  • Texas Office of Consumer Credit updates guidance urging property tax lenders to work with borrowers

    State Issues

    On October 27, the Texas Office of the Consumer Credit Commissioner updated its advisory bulletin urging property tax lenders to work with consumers during the Covid-19 crisis (previously discussed here and here) Among other measures, the regulator urges licensees to increase consumer communication regarding the effects of Covid-19 for licensees, work out modifications for payment difficulties, and review policies for fees, late charges, delinquency practices, and repossessions. The guidance also: (i) reminds licensees of legal requirements for using electronic signatures, and (ii) continues to permit licensees to conduct activity from unlicensed locations, subject to certain conditions. The guidance is in effect through November 30, 2020, unless withdrawn or revised.

    State Issues Covid-19 Consumer Credit Licensing Repossession ESIGN

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