Welcome to Hudson Cook Insights - a collection of articles written each month by the attorneys of Hudson Cook, LLP, in an effort to keep their clients and other compliance professionals informed about current trends and developments in consumer credit finance that will affect the way they do business.
Congress has responded to the economic crisis brought on by the COVID-19 virus by passing economic stimulus packages to help small and mid-sized businesses. Congress included in these packages $349 billion in Paycheck Protection Loans that will be forgiven so long as the loan funds are spent on certain specified costs and the business does not decrease the number of employees or cut employee wages by more than 25%. Congress also expanded the existing SBA Economic Injury Disaster Loan program to make it easier to obtain COVID-19 related disaster loans. article continued
As a supplement to its notice of proposed rulemaking on debt collection, on February 21, 2020, the Consumer Financial Protection Bureau issued additional proposed rules addressing attempts to collect debts for which the statute of limitations on collection has run. The proposed rules would apply only to persons who are "debt collectors" as defined under the federal Fair Debt Collection Practices Act. They were published to the federal register on March 3, 2020. The comment period on this supplemental rulemaking will run until June 5, 2020. article continued
Consumer Financial Protection Bureau has issued a request for information (RFI) to assist the Taskforce on Federal Consumer Financial Law with recommendations on harmonizing, modernizing, and generally improving the consumer financial laws. The Taskforce, on which I serve, is asking for input from the public on regulatory changes, clarifications, and other improvements that will enhance consumer financial protections. The Taskforce also welcomes recommendations for needed research and legislative changes. article continued
In response to the COVID-19 pandemic, creditors across the country are working to balance their business operations and servicing immediate consumer financial needs with public safety. Some creditors have begun offering forbearance agreements on loan payments or payment deferrals. Other creditors are considering options for loan modifications or extensions. As of March 30, 2020, at least two states had adopted guidance prohibiting repossession and other collection activity. article continued
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