On April 27, 2020, the OCC issued a bulletin (2020-45) to clarify and rescind its prior statement in Bulletin 2020-44, which was issued on April 25, 2020. The revised bulletin encourages banks providing loans under the SBA PPP to prudently document their implementation and lending decisions. Additionally, the bulletin further encourages banks to identify and track the PPP loans made to small business borrowers that have annual revenues of $1 million or less and are located in low- to moderate-income (LMI) areas.

On April 25, 2020, the FDIC updated their FAQs on the Small Business Administration’s Paycheck Protection Program. This FAQ answers several PPP related questions for FDIC-regulated financial institutions.

On April 24, 2020, the CFPB updated their guide to assist consumers in understanding their mortgage relief options during the COVID-19 pandemic. Originally published on March 31, 2020, the guide was updated on April 24, 2020, to add more information including updated information about forbearance options.

On April 16, 2020, the FDIC announced it will temporarily postpone its efforts to modify its signage and advertising requirements, known as the advertising of membership rules. In their release, the FDIC explained that they remain committed to modernizing these rules at a future date to better reflect how banks and savings associations are transforming their business models to take deposits via physical branches, digital, and mobile banking channels.

On April 21, 2020, the NCUA published a temporary final rule in the Federal Register that modifies certain regulatory requirements to help ensure that federally insured credit unions remain operational and liquid during the COVID-19 crisis. Specifically, the NCUA is temporarily raising the maximum aggregate amount of loan participations that a credit union may purchase from a single originating lender to the greater of $5,000,000 or 200 percent of the credit union’s net worth. The NCUA is also temporarily suspending limitations on the eligible obligations that a federal credit union may purchase and hold. In addition, given physical distancing policies implemented in response to the crisis, the NCUA is tolling the required timeframes for the occupancy or disposition of properties not being used for federal credit union business or that have been abandoned.