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Loans New Guidance

Sheppard Mullin Richter & Hampton LLP

States Sue the Biden Administration to Stop Loan Relief Plan

On April 9, 2024, seven states filed suit against the Biden administration in an attempt to block its new “SAVE” plan, an income-driven repayment plan that leads to eventual loan forgiveness. The case is pending in the U.S....more

Ballard Spahr LLP

OCC issues guidance on managing risks associated with “buy now, pay later” lending

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The Office of the Comptroller of the Currency (OCC) has issued a bulletin (2023-37) that provides guidance on managing risks associated with “buy now, pay later” (BNPL) lending.  The BNPL loans addressed in the bulletin are...more

Ballard Spahr LLP

Dept. of Education issues framework for student loan servicer accountability

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The White House signaled last week that, with the resumption of federal student loan payments, federal student loan servicers can expect to face increased scrutiny. The Department of Education issued a “Framework for Student...more

Cadwalader, Wickersham & Taft LLP

New Season, New Playbook September 2023 - Updated LSTA Regulatory Guidance – U.S. Sanctions Issues in Lending Transactions

The LSTA has regularly prepared and updated the LSTA Regulatory Guidance: U.S. Sanctions Issues in Lending Transactions (the “LSTA Guidance”). The LSTA Guidance contains a comprehensive review of sanctions, including...more

Troutman Pepper

OCC Issues Guidance on Applicability of Legal Lending Limit to Purchased Loans

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On August 8, the Office of the Comptroller of the Currency (OCC) issued guidance on the applicability of the legal lending limit (LLL) to purchased loans. This guidance applies to community banks’ purchases of loans. In...more

Proskauer Rose LLP

Paycheck Protection Program – SBA Clarifies PPP Guidance

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Third-Party Payroll Providers Cleared - On June 13, 2023, the U.S. Small Business Administration (“SBA”) issued new FAQ 72 (“FAQ 72”) to help clarify whether amounts paid by borrowers to third-party payers for the...more

Pullman & Comley - Labor, Employment and...

Mortgage or other Third Party Loan Investments in Your Plan?  Do they Pass Muster under IRS Issue Snapshot?

The IRS Issue Snapshot-Third Party Loans from Plans dated August 23, 2022 is a short advice document for examiners to use when auditing tax-qualified retirement plans that invest in mortgages or other third party loans. IRS...more

Foley & Lardner LLP

401(k) Compliance Check #7: Five Administrative Policies Every 401(k) Plan Needs

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To help employers properly administer their 401(k) plans, in 2022, Foley & Lardner LLP is authoring a series of monthly “401(k) Compliance Check” newsletters. This article discusses some of the policies that are important for...more

Harris Beach PLLC

New York State Court of Appeals Provides Guidance on Acceleration in Foreclosure Cases

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The New York State Court of Appeals recently provided much needed guidance to mortgagees on the issue of acceleration and determining the commencement date for the statute of limitation after acceleration in the decision...more

Goodwin

CFPB Grants No-Action Letter for Proposed Small-Dollar Credit Product

Goodwin on

In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more

Foley & Lardner LLP

SBA Guidance on Changes in Ownership of PPP Loan Borrowers

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On Friday, October 2, 2020, the Small Business Administration (“SBA”) issued a Procedural Notice (the “Notice”) providing guidance on the notification and consent requirements for changes in ownership of borrowers of...more

Butler Snow LLP

FFIEC Issues New Guidance on Loan Accommodations Related to COVID-19

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At the onset of the pandemic, many financial institutions offered credit accommodations, such as short-term deferrals and other loan modifications, to borrowers in response to the significant adverse impact caused by...more

Goodwin

It’s Time for a Fintech to Help Bank on Small-Dollar Lending in the U.S.

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As the U.S. wrestles with COVID-19, federal banking agencies are encouraging banks and credit unions to make responsible small-dollar loans to consumers and small businesses. Partnering with a financial technology company...more

Bracewell LLP

SBA Revises Certification Rules: Safe Harbor for Loans Under $2 Million, Larger Loans Still Subject to Audit

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The Small Business Administration has issued new guidance regarding the certification of necessity under the Paycheck Protection Program. Now, borrowers who received loans for less than $2 million -- roughly 98% of PPP loans...more

Ballard Spahr LLP

CFPB Issues HMDA Guides

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The CFPB recently issued the 2020 Filing Instructions Guide for Home Mortgage Disclosure Act (HMDA) data. The Guide applies to HMDA data collected in calendar year 2020 that must be reported to the government in 2021....more

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