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Today is: June 1, 2020  

Important Updates

COVID-19's Impact on Flood Insurance Regulations May 19, 2020

A question the law firm is frequently receiving during the pandemic is whether a COVID-19 loan modification triggers the flood insurance regulations. In short, the requirement to pull a Standard Flood Hazard Determination Form is triggered when a lender makes, increases, renews or extends (MIREs) a loan secured by a building or mobile home. If that building or mobile home is in a flood zone (what FEMA refers to as a “Special Flood Hazard Area” or “SFHA”), which is an A- or Vrated flood zone, the lender must send the SFHA notice. If the building or mobile home is also in an NFIP-participating community, then the loan is a “designated loan” and the lender must require flood insurance coverage. The flood escrow rules are triggered if a lender MIRES a designated loan secured by residential improved real estate or a mobile home after January 1, 2016, and none of the exceptions apply. In sum, all of these requirements hinge on whether the lender MIREd a loan. So, when a loan modification involves increasing, renewing or extending a designated loan, the flood insurance regulations are triggered. Read more.

CFPB Issues Guidance on 30-Day Deadline for Notice of Adverse Action on PPP Loans May 7, 2020

On May 6, 2020 the CFPB issued useful guidance on when the 30-day deadline to send a notice of adverse action under Regulation B starts to run on Paycheck Protection Program (PPP) applications. The news is good—PPP applications are not deemed “completed” until the SBA has issued a loan number for the loan or a response about the availability of PPP funds. This means PPP applications will not “time out” solely due to delays in receiving loan numbers from the SBA or during interim periods while the PPP has exhausted its funding. Read more.

Governor Exempts CARES Act Assistance Payments from Levy April 27, 2020

On April 23, 2020, California Governor Gavin Newsom signed Executive Order N-57-20 (“Order”) which exempts from garnishment federal, state or local government financial assistance payments received by individuals in response to the COVID-19 pandemic. This includes recovery rebates under the CARES Act (Coronavirus Aid, Relief, and Economic Security Act) whereby certain individuals are entitled to an advanced tax credit of up to $1,200, depending on their income level. Stated simply, the Order prevents debt collectors from garnishing federal stimulus funds from most Californians. Unfortunately, due to the broad and vague language used in the Order there are quite a number of unanswered questions that remain. Read more.

BCG Letters of Credit In-Person Seminar Locations Canceled - Additional Recording Playback Dates Added April 8, 2020

We want to advise you that we have canceled the in-person seminar locations for the BCG Letters of Credit Seminar in May.  Please note that we will automatically cancel your registration on our end, but we encourage you to register for any of the Recording Playbacks. Read more.

BCG Mortgage Lending Compliance In-Person Seminar Locations Canceled - Additional Recording Playback Dates Added March 23, 2020

We regret to inform you that we are canceling all of the in-person seminar locations for the April Mortgage Lending Compliance Seminar in recognition of the state and federal governments' requests to limit public gatherings. In their place we have scheduled four Recording Playback dates. Read more.

BCG Electronic Banking Seminar March 13, 2020

On March 11, 2020 we emailed a statement to our clients (and posted the statement on the BCG website) regarding our firm’s efforts to help contain the spread of the coronavirus.  At that time we had determined that we would not cancel any BCG Seminars scheduled for March. However, due to increasing concerns regarding public gatherings, we have decided to be more proactive and therefore we have canceled the remaining BCG Electronic Banking Seminars this month. Read more.

NFIP Extended Through September 30, 2020 December 23, 2019

On December 20, 2019, hours before the National Flood Insurance Program (NFIP) was set to expire, the President signed the “Further Consolidated Appropriations Act, 2020” (H.R. 1865) that, among other things, extended the NFIP for nine months through September 30, 2020. Read more.

NFIP Extended Through December 20, 2019 December 20, 2019

On November 21, 2019, hours before the National Flood Insurance Program (NFIP) was set to expire, Congress passed and the President signed an appropriations bill (H.R. 3055) that, among other things, extended the NFIP through December 20, 2019. Read more.

NFIP Extended Through November 21, 2019 October 01, 2019

On September 27, 2019, the President signed a bill (H.R. 4378) that, among other things, extended the National Flood Insurance Program (NFIP) through November 21, 2019. Without this bill, the NFIP was set to expire on September 30, 2019. The law firm will continue to monitor and report on the NFIP’s status. Read more.

Imposing PFI Review Fees June 26, 2019

Effective July 1, 2019, lenders must accept private flood insurance (PFI) on designated loans if the PFI policy meets the “Eight Criteria.” BCG members have asked whether they may charge a fee for this review – that is, whether they may charge a fee for reviewing a PFI policy to determine whether it meets the Eight Criteria. Read more.

New BCG Happenings! June 20, 2019

We are excited to announce our newest innovation in delivering BCG Seminars to BCG Members!

Beginning with the August Financial Privacy & Information Security Seminar, which will be presented by Robert Olsen and Keith Forrester, we will introduce a new feature to our BCG Seminars – it’s called the “Recording Playback.”

So what is this exactly?  We will record the monthly seminar ahead of time and host a Recording Playback for BCG Members (only) to attend on a specified date from 8:30 a.m. to 3:00 p.m., with scheduled breaks (including a lunch break) as we normally do at live seminars.  In addition, during the Recording Playback, we will provide several live Question & Answer Sessions during which attendees will be able to ask questions of the speakers. Read more.

NFIP Extended Through September 30, 2019 June 10, 2019

On June 3, 2019, Congress passed the Additional Supplemental Appropriations for Disaster Relief Act, 2019 (H.R. 2157), which, among other provisions, extends the National Flood Insurance Program (NFIP) through September 30, 2019. The president signed the bill on June 6, 2019, more than a week before the National Flood Insurance Program (NFIP) was set to expire. Read more.

Clarification: Annual Disclosure Requirement for State-chartered Banks May 10, 2019

In the April BCG Newsletter we reported that the FDIC issued a final rule eliminating the requirement that state nonmember banks prepare and make available an annual disclosure statement regarding the bank’s financial condition. Read more.

The Private Flood Insurance Compliance Aid Provision: It Does Exist! March 13, 2019

As we discussed during the February 2019 BCG Monthly Telephone Briefing and will discuss again during the BCG Webinar on April 30, 2019, starting July 1, 2019, regulated lenders must start accepting private flood insurance (PFI) policies that meet what we refer to as the “Eight Criteria.” Read more.



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