Troutman Pepper Consumer Financial Services COVID-19 Weekly – Coronavirus (COVID-19)

Worldwide: Troutman Pepper Consumer Financial Services COVID-19 Weekly

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Like most industries today, consumer finance service companies are significantly affected by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 resource center to guide clients through this unprecedented global health challenge. We regularly update this site with COVID-19 news and developments, recommendations from leading healthcare organizations, and tools businesses can use for free.

Our banking and loan clients are also facing new challenges affecting their industry as a result of COVID-19, particularly the ever-changing rules and regulations regarding evictions and foreclosures. We are following these updates closely and have assembled an interactive tracking tool containing state orders and guidance material regarding residential lockdowns and eviction moratoria. You can access this interactive tool at https://covid19.troutman.com/.

To help you stay on top of relevant activities, below is a breakdown of some of the biggest COVID-19-related events at the federal and state levels that have impacted the consumer finance services industry. last week :

Federal activities

State activities

Privacy and cybersecurity activities

Federal activities:

  • On June 4, the Consumer Financial Protection Bureau (CFPB) updated the frequently asked questions about compliance with the Electronic Funds Transfer Act (EFTA) and Regulation E. For more information, click on here.
  • On June 3, a group of homeowners challenging the Centers for Disease Control and Prevention’s eviction ban filed for an emergency appeal from the DC Circuit to the United States Supreme Court. The moratorium on evictions expires on June 30. For more information, click here.
  • On June 2, the Federal Reserve Board (Board) announced the approval of a final rule amending Regulation D to remove references to an interest rate on minimum reserves and an interest rate on excess reserves. and replace them with a single interest rate on reserve balances. . The final rule also simplifies the formula used to calculate the amount of interest paid on these balances and makes other minor conforming changes. The final regulation adopted the regulation proposed by the Council on January 8, 2021 without change, with the regulation taking effect on July 29. For more information, click here.
  • On June 2, the CFPB updated the Frequently Asked Questions on Compliance with the Mortgage Servicing Rule, Regulation X, and Regulation Z. here.

State activities:

  • On July 1, a new Nevada medical debt collection law will come into effect. By law, any debt owed for goods or services provided by a medical facility, health care provider, or emergency medical service provider is considered medical debt, except debts paid. through credit cards used to purchase other non-medical goods and services. For more information, click here.
  • On June 4, Executive Order No.243 from New Jersey Governor Philip Murphy came into effect. Among other mandates, this ordinance repealed the Exhibit Ordinance 107, which required businesses and nonprofits to “adapt their workforce to telework wherever possible.” . For more information, click here.
  • On June 1, the California assembly passed AB-1020 regarding billing and collection of health care debts, with the California Senate now ready to consider the bill. Under AB-1020, hospitals are required to have a written policy regarding the advance of patient debt for collection and are prohibited from pursuing collection action until 150 days after initial billing if the patient has no coverage or has high medical costs. For more information, click here.
  • On May 28, Massachusetts Governor Charles Baker issued an amended public health emergency and COVID-19 Order No. 69, which revoked the majority of COVID-19 orders. All but eight COVID-19 orders issued under the Civil Defense Act were revoked as of 12:01 am ET on May 29, 2021. For more information, click here and here.

Privacy and cybersecurity activities:

  • On June 3, the PCI Security Standards Council (PCI SSC) hosted a summit to discuss payment security in the pandemic era and after the pandemic. The PCI SSC discussed updates, including plans for the upcoming PCI Data Security Standard (PCI DSS). The leaders mentioned that “[c]Yber crime continued to rise during the COVID-19 pandemic, with criminals aggressively using old and new tricks, making it one of the biggest threats to economic recovery and continued business success.[.]”To read the full announcement, click on here.
  • On June 2, the Federal Trade Commission (FTC) warned consumers that con artists “are about to run their standard playbook” when they try to get individuals to forgo COVID-19 relief payments . The FTC reminds consumers that:
    • Only the IRS will send the payments; anyone else “tries to ‘help’ you get child tax credits really wants your money.”
    • The government will never contact you out of the blue to ask for money or personal information.
    • No one will require you to pay by gift card or wire transfer to get relief money.

For those who want to know more, click on here.

  • On June 2, seven countries in the European Union (EU) began using digital vaccine passport systems to verify people vaccinated against COVID-19. These seven countries (Bulgaria, Croatia, Czech Republic, Denmark, Germany, Greece and Poland) are the first of the 27 full EU Member States to use the system; all member states are expected to launch the system on July 1. The certificate will be used “in the form of a QR code, which can either be stored on a mobile phone or printed on paper. The data is not kept anywhere afterwards. [] for security and privacy reasons. ”For those interested in learning more about vaccination certificates and the potential implications of using them while traveling, check out Troutman Pepper’s Law360 item here. To read the full report, click here.

The content of this article is intended to provide a general guide on the subject. Specialist advice should be sought regarding your particular situation.

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