Washington Report 360 | April 4, 2020

Key highlights

• Treasury and the Small Business Administration have released an interim final rule and additional guidance for implementation of the Paycheck Protection Program (PPP), a loan program created by the CARES Act and slated to begin as early as April 3, 2020.
• Regulatory focus on CECL by the federal banking agencies included an optional two-year extension of the regulatory capital transition and a statement addressing the interaction of the regulatory rule with the CARES Act.
• SEC stated the June 30, 2020 compliance date for its Regulation Best Interest and related filing requirements “remains appropriate”

Financial services regulatory and policy news

Banking

• Federal banking agencies (FRB, FDIC, OCC):
  • Provided an optional extension for regulatory capital transition of CECL; permitted early adoption of SA-CCR
    FRB, FDIC, OCC, March 27, 2020
  • Clarified the interaction between the CECL interim final rule and the CARES Act
    FRB, FDIC, OCC, March 31, 2020
  • Amended the approach for calculating credit concentration risks
    FRB, FDIC, OCC, March 30, 2020
• FRB:
  • Established a temporary repurchase agreement facility for foreign and international monetary authorities (FIMA Repo Facility)
    FRB, March 31, 2020
  • Delayed its revised control framework for six months
    FRB, March 31, 2020
• CFPB:
  • Issued credit reporting guidance during COVID-19
    CFPB, April 1, 2020
  • Released its 2019 Consumer Response annual report
    CFPB, March 31, 2020
    
• FDIC highlighted Treasury and SBA lending programs
  FDIC, April 2, 2020

Capital markets

• Five agencies extend Volcker rule comment period
  FRB, FDIC, OCC, SEC, CFTC, April 2, 2020
• SEC stated Reg BI compliance remains June 30, 2020
  SEC, April 2, 2020
• CFTC issued additional targeted, temporary no-action relief to foreign affiliates of certain FCMs
  CFTC, March 31, 2020
• FINRA proposed to delay compliance with SR-FNRA-2019-014 for certain U.S. Treasury Securities transactions
  FINRA, April 1, 2020

Other

• Treasury and SBA publish interim final rule for Paycheck protection program
  Treasury, SBA, April 2, 2020
• BIS postponed Basel III implementation for one year
  BIS, March 27, 2020
• FTC released data showing jump in coronavirus-related consumer complaints
  CFTC, March 31, 2020

Industry news

• Emergency loan program plagued by chaos on eve of launch
  American Banker, April 3, 2020
• CECL impact delayed two years
  American Banker, March 27, 2020
• Ginnie Mae to help mortgage firms facing Coronavirus cash crunch
  WSJ, March 27, 2020
• The Fed Transformed: Jay Powell leads central bank into uncharted waters
  WSJ, March 30, 2020
• SEC Chairman: Government shouldn’t ban short selling in current market
  WSJ, March 30, 2020
• Surveillance of homebound wall street traders relies on pen and paper
  WSJ, March 30, 2020
• Uncertainty will exacerbate economic impact of virus: Fed paper
  Reuters, March 30, 2020
• Dealmaking grinds to a halt on coronavirus impact
  Financial Times, March 31, 2020
• Banks say Fed rescue threatens mortgage hedging strategies
  Financial Times, March 31, 2020

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