All Insights

PH FedACTion: Financial Regulatory Updates

Daily Financial Regulation Updates - Friday, April 10, 2020

April 11, 2020

By FedACTion Task Force

PH Client Alerts

to read more from our Coronavirus series.

Major Developments

COVID-19: Federal Reserve Bank of New York Releases FAQs on the Commercial Paper Funding Facility

April 10, 2020

The Federal Reserve Bank of New York (NY Fed) released FAQs relating tothe Commercial Paper Funding Facility (CPFF), which was authorized by the Board of Governors of the Federal Reserve System to address liquidity issues in the commercial paper market in the wake of COVID-19. The FAQs may be updated periodically and the New York Fed has added a sign-up for the CPFF daily purchase rates webpage, which will go live when the facility launches.


to view the full text of the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”), 116 HR. 748, Enacted March 27, 2020.

from the Senate Committee on Banking, Housing and Urban Development, Senate Committee on Small Business and Entrepreneurship, House Committee on Financial Services, and House Committee on Small Business.

Committee on Financial Services

COVID-19: Waters and Velázquez Write to Megabank CEOs to Express Strong Concerns About Small Business Access to Paycheck Protection Program

April 10, 2020

Congresswoman Maxine Waters (D-CA), Chairwoman of the House Financial Services Committee, and Congresswoman Nydia Velázquez (D-NY), Chairwoman of the House Small Business Committee, wrote to the Chief Executive Officers of Citigroup, JP Morgan Chase, Bank of America, and Wells Fargo to express their concerns regarding access to the Paycheck Protection Program (PPP) for small businesses and to request periodic updates on the banks’ participation in the program and related pandemic recovery efforts.

Federal Agencies

Department of Treasury

COVID-19: Treasury, IRS Launch Online Tool to Help Non-Filers Receive Economic Impact Payments

April 10, 2020

The U.S. Department of the Treasury and the Internal Revenue Service launched “Non-Filers: Enter Payment Info Here,” a web portal where Americans who did not file a tax return in 2018 or 2019 can submit basic personal information to the IRS so that they can receive Economic Impact Payments. Individuals can enter their bank account information and their payment will be directly deposited in their bank account.

Conference of State Bank Supervisors

COVID-19: CSBS President and CEO John Ryan Statement: Paycheck Protection Program Needs More Clarity and Guidance

April 9, 2020

Conference of State Bank Supervisors President and CEO John W. Ryan sent a letter to U.S. Treasury Secretary Steven Mnuchin and U.S. Small Business Administration Administrator Jovita Carranza urging more clarification and guidance on the $349 billion Paycheck Protection Program (PPP) established in the Coronavirus Aid, Relief, and Economic Security Act. The letter also calls for public disclosure of where PPP loans have been made.

Federal Deposit Insurance Corporation

COVID-19: Agencies Issue Joint Statement on Supervisory and Enforcement Practices Regarding the Mortgage Servicing Rules in Response to COVID-19 and the CARES Act

April 10, 2020

The Federal Deposit Insurance Corporation, the Consumer Financial Protection Bureau, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the National Credit Union Administration, and the Conference of State Bank Supervisors (the agencies) issued a joint statement on April 3, 2020 to announce their flexible supervisory and enforcement approach during the COVID-19 emergency regarding certain consumer communications required by the mortgage servicing rules. According to the statement, if a mortgage servicer provides a borrower a short-term forbearance payment option, the agencies do not intend to take supervisory or enforcement action for failing to meet certain timing requirements for consumer communications related to incomplete application acknowledgement, loss mitigation and early intervention, and annual escrow statements, provided that the servicer makes good faith efforts to provide these notices within a reasonable time.

COVID-19: Agencies to Host Banker Webinar: New Transition Provision to Delay the Impact of CECL on Regulatory Capital for Institutions Required to Adopt CECL in 2020

April 10, 2020

The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve, and the Office of the Comptroller of the Currency will jointly host a webinar to discuss a new transition provision in an interagency Interim Final Rule (IFR) to delay the impact that the current expected credit losses methodology (CECL) for estimating allowances for credit losses has on regulatory capital. The webinar is scheduled for Tuesday, April 14, 2020, at 3:00 p.m. ET.

COVID-19: FDIC and NCUA to Host Webinar for Consumers on Federal Deposit and Share Insurance

April 10, 2020

The Federal Deposit Insurance Corporation (FDIC) is hosting a free webinar in collaboration with the National Credit Union Administration (NCUA) to increase awareness of the benefits of federal deposit and share insurance, and answer questions about the safety of deposits at federally insured financial institutions. Representatives from the FDIC and NCUA will share tools, tip sheets, and other resources that can help consumers manage their household finances during the current national health emergency, and recognize potential fraud and scams. The webinar is open to the public and will be held Thursday, April 16, 2020 from 2:00 p.m. to 3:00 p.m. ET.

Securities and Exchange Commission

COVID-19: SEC Division of Corporation Finance Releases Statement Regarding Requirements for Form 144 Paper Filings in Light of COVID-19 Concerns

April 10, 2020

In recognition of the difficulties of submitting paper forms during the spread of COVID-19, the Division of Corporation Finance (DCF) of the Securities and Exchange Commission (Commission) issued a statement regarding filing of Forms 144 from and including April 10 to June 30, 2020. According to the statement, DCF staff will not recommend enforcement action to the Commission if a filer or submitter attaches a complete Form 144 as a PDF to an email sent to 


COVID-19: SEC Issues Investor Alert on Frauds Targeting Main Street Investors

April 10, 2020

The Securities and Exchange Commission’s Office of Investor Education and Advocacy (OIEA) and Retail Strategy Task Force issued an alert to educate Main Street investors about current investment frauds, including scams related to the Coronavirus (COVID-19) pandemic.

Commodity Futures Trading Commission

COVID-19: CFTC Extends Certain Comment Periods in Response to COVID-19

April 10, 2020

The Commodity Futures Trading Commission announced that it has voted to extend certain currently-open comment periods in light of the COVID-19 (coronavirus) pandemic. The extensions encompass rules proposed by the Division of Market Oversight (DMO) for which current comment periods started in January and February of 2020.

Consumer Financial Protection Bureau

COVID-19: Consumer Financial Protection Bureau Announces Guidance On Remittance Transfers During Covid-19 Pandemic

April 10, 2020

The Consumer Financial Protection Bureau (Bureau) issued a policy statement regarding steps it is taking to avoid disruptions in remittance transfers during the COVID-19 pandemic. The statement announces that, through January 1, 2021, the Bureau will neither cite supervisory violations nor initiate enforcement actions against certain remittance transfer providers in connection with an exception to a rule that is expiring in July of this year.

Federal Financial Institutions Examination Council

COVID-19: Consolidated Reports of Condition and Income: Revisions to the FFIEC Call Reports and FFIEC 101 for the March 31, 2020, Report Date

April 10, 2020

The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation published a set of supplemental instructions on the Federal Financial Institutions Examination Council (FFIEC) website to assist financial institutions in completing the first-quarter Consolidated Reports of Condition and Income (call report).

Ginnie Mae

COVID-19: Ginnie Mae Announces Changes to its Pass-Through Assistance Program in Response to COVID-19 National Emergency

April 10, 2020

Ginnie Mae issued All Participants Memorandum (APM) 20-03, which announces the expansion of its Issuer assistance programs in response to the COVID-19 National Emergency. The APM introduces a new version of the existing Pass-Through Assistance Program (PTAP) for use by issuers facing a temporary liquidity shortfall directly attributable to the COVID-19 National Emergency. The application of PTAP to the COVID-19 National Emergency (PTAP/C19) allows Issuers to apply for assistance in meeting their contractual obligation to make timely and in full principal and interest payments due mortgage-backed security (MBS) holders without being held in default under the Ginnie Mae Guaranty Agreement.

Department of Labor


April 10, 2020

The U.S. Department of Labor’s Employment and Training Administration (ETA) announced the publication of Unemployment Insurance Program Letter (UIPL) 17-20, which provides further guidance to states as they implement the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), including the Pandemic Emergency Unemployment Compensation (PEUC) program.

Get In Touch With Us

Contact Us