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  • FDIC posts Covid-19 FAQs for bankers and bank customers

    Federal Issues

    On March 19, the FDIC issued FIL-18-2020, which highlights frequently asked questions for bank customers and banks affected by Covid-19. The FAQs, are available on the FDIC’s Covid-19 webpage. Bank customer FAQs cover questions regarding (i) deposit insurance; (ii) customer access to money; (iii) tips for avoiding scams; and (iv) identity theft, among other things. The FAQs for financial institutions cover topics including working with borrowers affected by Covid-19 through payment accommodations, reporting delinquent loans,  and operational issues affecting institutions.

    Federal Issues Agency Rule-Making & Guidance Privacy/Cyber Risk & Data Security FDIC Consumer Finance Covid-19

  • Fed agencies issue regulatory capital interim rule

    Federal Issues

    On March 19, the OCC, the Fed, and the FDIC announced the release of an interim final rule for the Money Market Mutual Fund Liquidity Facility (MMLF) which revises capital rules for activities with the MMLF. The agencies issued the rule to enable financial institutions to “effectively use” the MMLF following its launch by the Fed on March 18. Pursuant to the Federal Reserve Act, the Fed granted authority to establish the MMLF to the Federal Reserve Bank of Boston, allowing it to provide “non-recourse loans to eligible institutions” secured by assets those institutions buy from money market mutual funds. The rule will allow financial institutions to participate because activities with the MMLF will “neutralize the regulatory capital effects of participating in the program” on the institution. The rule is effective immediately and there will be a 45-day comment period.

    Federal Issues Agency Rule-Making & Guidance OCC Federal Reserve FDIC Mutual Fund Covid-19

  • Fed announces temporary swap lines with nine countries

    Federal Issues

    On March 19, the Federal Reserve announced the establishment of temporary U.S. dollar liquidity arrangements (swap lines) with the Reserve Bank of Australia, the Banco Central do Brasil, the Danmarks Nationalbank (Denmark), the Bank of Korea, the Banco de Mexico, the Norges Bank (Norway), the Reserve Bank of New Zealand, the Monetary Authority of Singapore, and the Sveriges Riksbank (Sweden). These facilities are designed to “help lessen strains in global U.S. dollar funding markets, thereby mitigating the effects of these strains on the supply of credit to households and businesses, both domestically and abroad.”

    Federal Issues Covid-19 Federal Reserve

  • Mississippi governor orders restrictions on social gathering and non-essential business

    State Issues

    On March 24, Mississippi Governor Tate Reeves ordered certain restrictions on social gatherings and restrictions on certain non-essential businesses.  Any “Essential Business or Operation” may perform services or functions without regard to the limitations. Financial services, including banks, insurance, payroll, accounting, and processing services related to financial markets, and real estate services, including appraisal and title services, are deemed Essential Business.

    State Issues Covid-19 Mississippi Bank Compliance

  • Arizona governor postpones eviction actions

    State Issues

    On March 24, the governor of Arizona issued an executive order instructing law enforcement officers to delay for 120 days any enforcement of eviction orders for residential premises occupied by certain individuals impacted by Covid-19. The order applies when the individual is required to be quarantined due to her own or someone in her home’s Covid-19 diagnosis, ordered by a medical professional to self-quarantine, and demonstrates that they are at high risk for Covid-19 due to a health condition, or has suffered a substantial loss of income due to Covid-19. 

    State Issues Arizona Consumer Finance Covid-19

  • New Mexico banking regulator offers guidance on conducting business during Covid-19 crisis

    State Issues

    On March 24, the New Mexico Regulation and Licensing Department, Financial Institutions Division (FID) issued guidance encouraging financial institutions licensed in New Mexico to work with customers experiencing hardship due to Covid-19, while maintaining the overall safety of the financial institution.

    State Issues Covid-19 New Mexico

  • New Mexico banking regulator confirms financial institutions are essential business

    State Issues

    On March 24, the New Mexico Regulation and Licensing Department, Financial Institutions Division (FID) issued guidance confirming that, for purposes of the public health order closing all non-essential business in New Mexico, all depository and non-depository financial institutions licensed and regulated by the FID are considered “essential business” and are not subject to the order. The guidance also encourages institutions to work with customers in a manner that maintains the overall safety of the financial institution.

    State Issues Covid-19 New Mexico

  • Wyoming secretary of state announces temporary remote notarization

    State Issues

    On March 24, Wyoming’s secretary of state issued guidance on temporary remote notarization as a result of Covid-19. The guidance encourages Wyoming-based notaries that intend to perform remote online notarial acts to undergo training from remote notarization providers approved by contiguous states, and use that provider’s technology standards and security features. Approved contiguous providers include: CSC Global, Figure Technologies, Nexsys, NotaryCam, SafeDocs, Simplifile (for IPEN only), DocVerify, Jetexas Information Technovation, Notarize, Pavaso, SIGNiX, and World Wide Notary.

    State Issues Covid-19 Wyoming Notary Fintech

  • Massachusetts Securities Division relaxes notarization and signature requirements for certain filings

    State Issues

    On March 24, the Massachusetts Securities Division issued an Emergency Notice giving temporary relief from certain filing requirements for corporate finance filings and financial professional registrations during the Covid-19 outbreaks. The Division will not require manual signatures or notarizations for securities registration applications, exemption filings, securities notice filings, and consent to service of process forms and will accept e-signatures and copies of signed documents where required. The Division will also permit electronic submission of Forms U4 without physical signatures from individual agents or investment advisor representatives, provided that certain requirements are met, and will accept alternatives to a notarized Criminal Offender Record Information acknowledgment form. Finally, the Division will allow investment advisers up to 45 additional days to perform any Form ADV filing, updating, or customer delivery requirements. This guidance will remain in effect until April 30, unless extended or rescinded.

    State Issues Covid-19 Massachusetts Securities Notary E-Signature

  • Iowa Superintendent of Banking provides update on Covid-19 response

    State Issues

    On March 24, Iowa’s Superintendent of Banking sent an update letter to bank presidents and CEOs concerning the state’s Covid-19 response efforts. The update highlighted, among other things, the following: (i) loan and grants available to small businesses through state and federal programs; (ii) the governor’s suspension of foreclosures and evictions in the state; (iii) the Division of Banking’s temporary suspension of requirement for in-person annual meetings; (iv) the governor’s outreach to county auditors, recorders and treasurers asking them to facilitate full range of vital mortgage-related services; (v) ongoing efforts to refine the offsite exam process; and (vi) guidance at the federal level from the Treasury Department and the March 22 Interagency Statement regarding loan modifications and troubled debt restructurings (covered by InfoBytes here).

    State Issues Iowa Covid-19 Debt Relief Loan Modification

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