Today, May 5, 2020, the federal banking agencies released an interim final rule to neutralize the effect of participating in the Paycheck Protection Program Liquidity Facility (“PPPLF”) and Money Market Liquidity Facility (“MMLF”) on a banking organization’s Liquidity Coverage Ratio (“LCR”).
Continue Reading LCR Effects of PPPLF and MMLF Participation Neutralized
CARES Act
Federal Reserve to Disclose Information on Borrowers of Emergency Lending Programs
Posted in Regulatory Agencies
On April 23, 2020, the Federal Reserve Board (“Board”) announced that it will provide “extensive” public information on the borrowers, interest rates, and loan amounts pertaining to the funding from the coronavirus emergency lending programs.
Continue Reading Federal Reserve to Disclose Information on Borrowers of Emergency Lending Programs
CFPB Releases Guidance on FCRA and Regulation V Compliance During COVID-19
By Andrew Soukup, David Stein & Lucille Bartholomew on
On April 1, 2020, the Consumer Financial Protection Bureau (“CFPB”) released a statement on “Supervisory and Enforcement Practices Regarding the Fair Credit Reporting Act and Regulation V in Light of the CARES Act.” This statement provides guidance outlining the CFPB’s expectations of furnishers and consumer reporting agencies (“CRAs”) during the COVID-19 pandemic, and signals that the CFPB will take a flexible supervisory and enforcement approach to compliance with the Fair Credit Reporting Act (“FCRA”) and its implementing regulation, Regulation V.
The key points of the CFPB’s guidance are discussed below.
Continue Reading CFPB Releases Guidance on FCRA and Regulation V Compliance During COVID-19