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Proposed Third-Party Relationships Guidance Comment Period Extended

On July 13, 2021, the Board of Governors of the Federal Reserve (the "Fed"), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (the OCC, collectively referred to herein with...more

9/9/2021  /  Comment Period , FDIC , FinTech , Third-Party

New Guidance for Banks Engaging with FinTechs

On August 27, 2021, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency issued new guidance to community banks for conducting due...more

New Proposed Guidance on Third-Party Relationships

On July 13, 2021, the Board of Governors of the Federal Reserve (the "Fed"), the Federal Deposit Insurance Corporation (the FDIC) and the Office of the Comptroller of the Currency (the OCC), with the Fed and the FDIC...more

True Lender Rule May Be Repealed

As most financial institutions and lenders are aware, in October 2020 the Office of the Comptroller of the Currency (the OCC) issued a rule that required the identification of the "true lender" of a loan to a customer if the...more

Paycheck Protection Program: A Second Round of Funding for Some New and Existing Borrowers; Other Changes to Benefit All Borrowers

On December 27, 2020, President Trump signed the Consolidated Appropriations Act, 2021 (the "Appropriations Act"), which includes a new round of funding for certain qualifying, existing Paycheck Protection Program (PPP)...more

Main Street Lending: Practical Insights

For six months, the Federal Reserve has been developing and refining the products, purpose and eligibility for the Main Street Lending Program. The portal finally opened for loans at the end of July, and in September, the...more

Main Street Lending Program is Operational

The Federal Reserve Bank of Boston announced yesterday that it is ready to purchase participations in loans originated by eligible lenders under the Main Street Lending Program (the MSLP). The Federal Reserve also announced...more

SBA Issues New Paycheck Protection Program Forgiveness Applications and Forgiveness Guidance

As a result of the passage of the Paycheck Protection Program Flexibility Act (the "Flexibility Act"), the SBA has issued two new Forgiveness Applications and provided additional guidance on forgiveness under the Paycheck...more

Congress Makes Significant Changes to Paycheck Protection Program

Since the Small Business Administration (SBA) and United States Treasury (Treasury) issued the first Interim Final Regulations on April 2, 2020 under the Paycheck Protection Program (PPP), borrowers, potential borrowers and...more

Regulators Issue Small Dollar Lending Principles

Earlier in March, the Federal Reserve Board (FRB), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA) and Office of the Comptroller of the Currency (OCC and collectively with the FRB,...more

Welcome News on PPP Need Certification: Safe Harbor for Loans Below $2 Million, More Clarity for Loans Above $2 Million

Earlier today, the Small Business Administration (SBA) issued FAQ 46 that provides additional guidance related to the certification of need that is required for a Paycheck Protection Program (PPP) loan. As we discussed in a...more

Federal Reserve Board Expands Main Street Lending Program

On April 30, 2020, the Federal Reserve Board (FRB) announced an expansion in the scope and eligibility of the Main Street Lending Program (MSLP). The FRB previously provided term sheets on two facilities under the MSLP and...more

CARES Act Paycheck Protection Program Applications Now Available: Guidance for Lenders and Borrowers

On April 2, the Small Business Administration (SBA) issued an Interim Final Rule (the Rule) implementing the Paycheck Protection Program (PPP) created under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act)....more

CARES Act: Understanding SBA Loan Programs to Determine Eligibility and Best Fit for Your Company

As a result of the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) passed by the Senate on Wednesday March 25, 2020 and expected to be passed by the House of Representatives and signed into law by the...more

Alabama's Data Breach Notification Law Takes Effect June 1, 2018

On March 28, Alabama Governor Kay Ivey signed SB 318, the Alabama Data Breach Notification Act of 2018, which becomes effective on June 1, 2018. Alabama was the final state to enact a data breach notification law, and many...more

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