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PH FedACTion: Financial Regulatory Updates

Daily Financial Regulation Update - Wednesday, June 3, 2020

June 03, 2020

FedACTion Task Force

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PH Client Alerts

Click here to read more from our Coronavirus series.

Congress

Click here to view the full text of the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”), 116 HR. 748, Enacted March 27, 2020.

Click here to view the full text of the Paycheck Protection Program Increase Act of 2020, Enacted April 24, 2020.

Click here to view a running list of proposed legislation from the Senate Committee on Banking, Housing, and Urban Affairs, Senate Committee on Small Business and Entrepreneurship, House Committee on Financial Services, and House Committee on Small Business.

Federal Agencies

Federal Reserve Board

Coronavirus Pandemic Oversight Challenges

June 2, 2020

The Office of the Inspector General of the Board of Governors of the Federal Reserve System (“Board”) issued a release on coronavirus pandemic oversight challenges. According to the release, the scope of the Board’s response so far and its potential future actions must properly address the significant challenges ahead for the broader economy as well as the requirements of the CARES Act.

Consumer Financial Protection Bureau

CFPB Provides Guidance on Remittances during COVID-19 Pandemic

June 2, 2020

The Consumer Financial Protection Bureau issued Frequently Asked Questions (“FAQs”) on remittances during the COVID-19 pandemic. The FAQs clarify that the failure to deliver remittance transfer funds to a designated recipient by the disclosed date of availability, due to government-mandated closure of commercial activity in the relevant intermediary or recipient countries in response to the COVID-19 pandemic, is not an error under the Remittance Rule if the remittance transfer provider could not have reasonably anticipated the closure. The FAQs also include illustrative examples.

International

Bank of England Prudential Regulation Authority

PRA Statement on the Use of Electronic Signatures to Evidence Forms and Other Documents Delivered to the PRA

June 2, 2020

The Prudential Regulation Authority (“PRA”) released a statement that provides information on the use of electronic signatures in relation to the submission of forms and other regulatory documents to the PRA. The PRA confirms that, in the absence of any specific legal provisions to the contrary, firms may use electronic signatures for the submission of forms and regulatory documents, although it may in specific instances request a “wet signature” where it is appropriate to do so. The PRA will review the approach in light of evolving work practices.

UK Financial Conduct Authority

FCA Confirms Support for Customers who are Struggling to Pay their Mortgage Due to Coronavirus

June 2, 2020

The Financial Conduct Authority (“FCA”) confirmed the support firms should give to mortgage customers who are either coming to the end of a payment holiday or who are yet to request one. The FCA also reminded customers that they should resume payments if they can afford to do so.