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Bank Law Monitor

A legal blog for the financial services industry

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More COVID Relief in Sight as Congress Amends the Paycheck Protection Program
The “Consolidated Appropriations Act, 2021” (CAA), which includes provisions designed to mitigate the ongoing economic fallout of COVID-19, became law on December 27, 2020. While most of the public’s attention is on other of the CAA ’s benefits —li...
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Oregon Governor Issues Executive Order Related to Foreclosure Moratorium
On December 17, 2020, Governor Kate Brown issued an executive order related to Oregon’s foreclosure moratorium (HB 4204). Under Executive Order 20-67 (EO 20-67), Governor Brown determined that a state of emergency continues to exists in the State of...
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Oregon Presses Pause on Foreclosures, Payment Defaults, and Evictions
In an effort to provide relief to homeowners, businesses, landlords, and tenants affected by COVID-19, Governor Brown signed two bills that impose significant limitations on lenders and landlords. Under HB 4204, lenders cannot foreclose on loans secu...
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At Long Last, FinCEN Offers Much Awaited Guidance Regarding BSA Due Diligence Requirements for Hemp Businesses
Ever since Congress passed the 2018 Farm Bill and hemp was declassified under federal law as a Schedule I controlled substance, financial institutions have struggled with whether and how to bank the hemp industry. Many bankers simply feared that the...
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“First Come, First Served:” SBA Issues Critical Guidance for Payroll Protection Program Loans
The Small Business Administration (SBA) has issued an Interim Final Rule controlling how $349 billion in short-term business loans under the CARES Act will be allocated. While the SBA is seeking comments from the public, the rule is effective immedia...
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Federal Banking Agencies Encourage Small-Dollar Lending
No, your eyes aren’t deceiving you. On Thursday, March 26, 2020, the federal banking agencies (i.e., the FDIC, CFPB, FRB, NCUA, and OCC) issued a joint statement encouraging banks and credit unions to offer responsible small-dollar loans to consumers...
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