A&B ABstract: In response to COVID-19, on Friday March 28, 2020, President Trump signed into law the “Coronavirus Aid, Relief, and Economic Security Act” (the “CARES Act”). This is a monumental $2 trillion stimulus package intended to provide financial relief to businesses, individuals and public institutions affected by the coronavirus. The CARES Act addresses sweeping […]
Mortgage Loans
Federal and State Guidance Regarding the COVID-19 Pandemic
A&B Abstract: The Alston & Bird Consumer Finance team recognizes that this is a period of great uncertainty both for the nation and our clients. We have received numerous questions and concerns regarding what federal and state regulators are doing in light of the COVID-19 pandemic and how their response may affect day-to-day business. We […]
New York Financial Regulator Requires COVID-19 Risk Assessment, Operational Planning
Last week the New York Department of Financial Services (the “Department”) issued letters to all its licensed financial institutions. Based on these letters (available here and here), all Department licensees must assess and plan for the financial risk of COVID-19 and, separately, develop operational plans for managing their response to the virus. The Department requires written responses “as […]
Coronavirus and Securitization: Disclosure and Diligence Issues
Mortgage-backed and asset-backed securities are beginning to feel the effects of quarantines and social distancing as people spend – and earn – less money. Our Finance Group explores the basic disclosures to consider with any securitization and how best to address them during the coronavirus pandemic. Four disclosure issues for securitization Two key diligence issues […]
NYDFS Extends Transition Period for Part 419 Compliance by Additional 90 Days
On March 13, 2020, the New York Department of Financial Services (“NYDFS”) adopted, on an emergency basis, amendments (the “Emergency Adoption”) to the final mortgage servicer business conduct rules found in Part 419 of the Superintendent’s Regulations (the “Final Rules”), to extend the transition period for compliance with the Final Rules by an additional 90 […]