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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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Banking Regulators Encourage Lenders to Work with Borrowers Impacted by COVID-19
Federal banking regulators took a bold, first step this past Sunday, announcing Interagency Guidance ("the Guidance") to encourage lenders to work with borrowers impacted by the COVID-19 outbreak.[1] The Guidance specifically permits lenders to enter...
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FinCEN Reverses Course on Beneficial Ownership Requirements in Connection with Loan Renewals and Modifications
It can be hard for regulatory agencies to admit when they’ve made a mistake. But that’s exactly what FinCEN did last week when it announced that certain loan renewals and modifications[1] would not trigger its beneficial ownership due diligence rule...
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