On April 7, 2020, the CFPB issued a revised interagency statement encouraging financial institutions to work constructively with borrowers affected by COVID-19 and providing additional information regarding loan modifications. The revised statement also provides the agencies’ views on consumer protection considerations.

With the implementation of the Paycheck Protection Program, the Small Business Administration (SBA), in consultation with the Department of the Treasury, has provided an continuously updated additional guidance to address borrower and lender questions concerning the implementation of the Paycheck Protection Program (PPP). The Treasury’s FAQ document will be updated on a regular basis and both borrowers and lenders are permitted to rely on the guidance provided in FAQ as SBA’s interpretation of the CARES Act and of the Paycheck Protection Program Interim Final Rule. The U.S. government will not challenge lender PPP actions that conform to the Treasury’s guidance, and to the PPP Interim Final Rule and any subsequent rule-making in effect at the time. As of April 8, 2020, the FAQ contained 20 frequently asked questions and answers.

On 4/3/2020, the CFPB released its annual report about the work of its Office of Servicemember Affairs (OSA) over the past fiscal year to help servicemembers, veterans, and their families achieve financial well-being. As noted in the report, this work has included education, outreach, coordination with other federal and state agencies, and monitoring complaints submitted by servicemembers, veterans, and their families.

On 4/6/20, the Department of Labor published temporary regulations in the Federal Register to implement public health emergency leave under Title I of the Family and Medical Leave Act (FMLA), and emergency paid sick leave to assist working families facing public health emergencies arising out of Coronavirus Disease 2019 (COVID-19) global pandemic. The leave is created by a time-limited statutory authority established under the Families First Coronavirus Response Act, (FFCRA), and is set to expire on December 31, 2020. The FFCRA and this temporary rule do not affect the FMLA after December 31, 2020.

On 4/3/2020, the regulators jointly issued a policy statement providing needed regulatory flexibility to enable mortgage servicers to work with struggling consumers affected by the Coronavirus Disease (referred to as COVID-19) emergency. The guidance informs servicers of the regulators’ flexible supervisory and enforcement approach during the COVID-19 emergency regarding certain communications to consumers required by the mortgage servicing rules. The policy statement and guidance will facilitate mortgage servicers’ ability to place consumers in short-term payment forbearance programs such as the one required by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).

On 4/3/20, the FDIC announced that it will extend the public comment period for its proposed rule to modernize its brokered deposit regulations by 60 days. Interested parties responding to the FDIC’s proposal may now submit comments through June 9, 2020.