On April 16, 2020, the NCUA approved several regulatory relief measures to assist credit unions during the COVID-19 pandemic including: 1). A temporary final rule granting measures of regulatory relief to help ensure that federally insured credit unions remain operational and liquid during the COVID-19 pandemic. 2) An interim final rule that temporarily defers real estate-related appraisals and evaluations under the agency’s appraisal regulations because the public health crisis and social distancing directives have created difficulties for lenders to obtain required appraisals on a timely basis. 3) A final rule that increases the threshold level below which appraisals would not be required for residential real estate-related transactions from $250,000 to $400,000.

On 4/16/20, the Small Business Administration (SBA) updated its website to reflect the fact that all available funds for the PPP program have been used up. Specifically, the SBA placed the following notice on its website:

“Lapse in Appropriations Notice: SBA is unable to accept new applications at this time for the Paycheck Protection Program or the Economic Injury Disaster Loan (EIDL)-COVID-19 related assistance program (including EIDL Advances) based on available appropriations funding.

On April 10, 2020, the CFPB issued a policy statement to ensure that consumers will be able to continue to send remittance transfers without disruption during the COVID-19 pandemic. More information can be found by clicking this link.

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.