On July 7, 2020 (CA 20-11), the Board of Governors of the Federal Reserve (Board) recently developed examination procedures for the credit reporting and mortgage servicing provisions of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The CARES Act was signed into law on March 27, 2020, to provide relief to those who are impacted by the Coronavirus Disease 2019 (COVID-19) emergency. Among other things, the CARES Act created new responsibilities for furnishers of certain credit information and for mortgage servicers of certain mortgage loans.
When exercising supervisory and enforcement responsibilities, the Board will take into account the unique circumstances impacting borrowers and institutions resulting from the COVID-19 emergency. The Board will take into account an institution’s good faith efforts demonstrably designed to support consumers and comply with consumer protection laws. The Board expects that supervisory feedback for institutions will be focused on identifying issues, correcting deficiencies, and ensuring appropriate remediation to consumers. The Board does not expect to take a consumer compliance public enforcement action against an institution, provided that the circumstances were related to the COVID-19 emergency and that the institution made good faith efforts to support borrowers and comply with the consumer protection requirements, as well as responded to any needed corrective action.
InCompliance Newsletter - Subscribe Here