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Florida State Department extends annual filing deadlines to June 30
On March 27, Florida’s secretary of state issued an emergency order postponing the annual report filing deadlines for businesses. The order extends reporting deadlines to June 30, unless an additional extension is granted through a subsequent order.
Texas Office of Consumer Creditor Commissioner issues annual report deadline information
On March 27, the Texas Office of Consumer Creditor Commissioner updated a previous property tax lender advisory bulletin to include annual report deadline information. Recognizing that property tax lenders may need additional time to file annual reports, in light of disruptions caused by Covid-19, the March 31 deadline has been extended to April 30.
Washington governor issues real estate and mortgage guidance
On March 27, Governor Jay Inslee issued guidance on conducting real estate and mortgage transactions. The guidance declares that in-person meetings with customers, except when necessary for a customer to view a property or sign necessary documents, are prohibited, as are open-houses. Property viewings, inspections, appraisals, and final walk-throughs shall be arranged by appointment and limited to no more than two people on site at any one time. Except for the limited exceptions authorized above, all new real estate listings shall be facilitated remotely.
Wisconsin issues temporary ban on evictions and foreclosures
On March 27, Wisconsin issued a temporary ban on foreclosures on real estate, on mortgagees requesting or scheduling a foreclosure sale, and on evictions for failure to pay rent. The order will remain in effect for 60 days.
Ohio Department of Commerce, Division of Financial Institutions issues guidance regarding branch closures
The Ohio Department of Commerce, Division of Financial Institutions issued guidance to assist financial institutions when making the decision to limit branch operations or to close a branch. The Division advised that temporary closures of banking office locations for 48 hours or less must be reported to the Division and closures lasting longer than 48 hours must receive advance permission.
New York governor issues executive order to continue temporary suspension and modification of laws relating to Covid-19
On March 27, the New York governor issued Executive Order 202.11 continuing the temporary suspension and modification of certain laws, including the expiration date of certain licensing laws, through April 26.
Colorado regulator issues appraisal guidance for banks and credit unions
On March 27, Colorado’s Division of Banks and Division of Financial Services distributed a document consolidating Covid-19 related guidance regarding inspections and appraisals from the Appraisal Standards Board, Fannie Mae, Freddie Mac, and the FDIC. Taken together, the agencies have issued guidance indicating that they will accept external-only or desktop inspections and appraisals in light of risks of conducting interior inspections during the Covid-19 outbreak.
Maryland banking regulator outlines expectation for working with borrowers
On March 27, Maryland’s Commissioner of Financial Regulation issued an industry advisory with guidance regarding consumer credit for borrowers impacted by Covid-19. The guidance warns licensees against using the health crisis as an opportunity to increase fees or interest rates and instructs them to keep applicants and clients informed of disruptions or delays in credit decisions or changes to times and methods of communication. The advisory also “strongly urges” licensees to takes steps to mitigate the health crisis by, among other things: waiving late fees and online and telephone payment fees; foregoing credit reporting or reporting payment information in a manner that minimizes negative impact on credit histories; offering modification, forbearance or other options to allow borrowers to reduce or defer payments; ensuring that borrowers are able to timely make inquiries and manage their accounts; reaching out to borrowers proactively to provide information on available assistance; and ensuring that all borrower-facing staff are fully informed regarding available assistance and proactive in informing borrowers. Licensees are reminded to comply with applicable Maryland law, including all fair lending requirements, and to retain appropriate documentation to support decisions regarding mitigation offers.
California governor issues executive order halting enforcement of evictions
On March 27, the California Governor issued an executive order halting the enforcement of eviction orders for renters affected by Covid-19 through May 31, 2020. The order prohibits landlords from evicting tenants for nonpayment of rent and prohibits enforcement of evictions. It also requires tenants to declare in writing, no more than seven days after the rent comes due, that the tenant cannot pay all or part of their rent due to Covid-19.
FDIC issues statement on Part 363 annual reports in response to Covid-19
On March 27, the FDIC issued a Financial Institution Letter providing additional information and guidance to insured depository institutions (IDIs) subject to Part 363 of the FDIC regulations that have been affected by Covid-19. The FDIC will not take supervisory action against an IDI for submitting its Part 363 Annual Report or its written notification of late filing as long as the annual report or notification of late filing is submitted within 45 days of the 90- or 120-day report filing deadline. IDIs are encouraged to contact the FDIC in advance of the official filing date if the IDI anticipates delayed submission. This letter applies to all insured depository institutions with $500 million or more in total assets.