Federal Reserve Issues Guidance on FEMA’s 120-Day Payment Grace Period

May 6, 2020

The Federal Reserve issued guidance providing regulated lending institutions direction on how to handle lender placement of flood insurance in response to FEMA extending the NFIP policy payment grace period from 30 to 120 days. The guidance is in the form of FAQs issued to address general COVID 19 relief. Similar to the OCC’s directives […]

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DC Prohibits Cancellations and Nonrenewals of Policies for Nonpayment

May 1, 2020

The District of Columbia Acting Commissioner issued an order prohibiting all property and casualty insurers authorized to conduct business in the District from canceling and nonrenewing insurance policies for nonpayment of premiums. Additionally, insurers are instructed to provide reasonable accommodations, including waiving late fees for unpaid premiums and providing insureds the option to repay unpaid […]

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CFPB Issues Guidance on Servicing Transfer Process

April 29, 2020

The Consumer Financial Protection Bureau (CFPB) published a compliance bulletin and policy guidance pertaining to residential mortgage loan servicing transfers with the intent of providing clarity, enhancing compliance, and preventing harm to consumers. The Bureau based its guidance on examination findings of inadequate policies and procedures related to the transfer of information between servicers, and stresses […]

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New York Department of Financial Services order for those directly impacted by COVID-19  

April 28, 2020

A recent Executive Order issued by Governor Cuomo, together with recent amendments to the insurance and banking regulations (the “regulations”) issued by the New York State Department of Financial Services (“Department”), extend grace periods and give you other rights under certain property/casualty insurance policies if you are an individual or small business and can demonstrate […]

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FHFA Addresses Servicer Liquidity Concerns

April 27, 2020

In efforts to address forbearance liquidity concerns posed by the industry, the Federal Housing Finance Agency (FHFA) announced changes to guidelines that limit the number of advance monthly principal and interest payments servicers will be required to send to investors on single-family mortgage loans in forbearance. These revisions align Fannie Mae’s policy with that of […]

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OCC Guidance on FEMA’s 120-Day Payment Grace Period

April 27, 2020

As previously communicated by Proctor, on March 29, 2020, the Federal Emergency Management Agency (FEMA) extended the NFIP policy payment grace period from 30 to 120 days. The grace period is applicable to policies that expire between February 13, 2020 and June 15, 2020. Recently, the OCC provided guidance to mortgage industry groups that gives regulated […]

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Oklahoma Issues Bulletin Granting 45-Day Grace Period

April 9, 2020

In response to the public health disaster emergency declaration for the novel coronavirus disease (COVID-19), the Oklahoma Insurance Department issued bulletins (2020-01/2020-01 Amended), directing all property and casualty insurers providing coverage to Oklahoma residents to extend grace periods to pay insurance premiums by 45-days so that policies are not cancelled for nonpayment during this state […]

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FEMA Extends Grace Period for Flood Insurance Premiums

April 2, 2020

In response to the COVID-19 pandemic, the Federal Emergency Management Agency (FEMA) issued Bulletin W-20002 announcing an extension of the premium payment grace period from 30 to 120 days. The bulletin applies to Write Your Own and Direct National Flood Insurance Program (NFIP) policies. The Bulletin provides that policies renewing with an expiration date between February […]

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Alaska Issues Bulletin Prohibiting Cancellation for Nonpayment

April 1, 2020

In response to the public health disaster emergency declaration for the novel coronavirus disease (COVID-19), the Alaska Division of Insurance issued a bulletin (Bulletin B 20-08) prohibiting insurers from cancelling insurance policies for nonpayment of premiums. To clarify, this directive does not remove the insureds obligation to pay premiums; instead, it limits policy cancellations for […]

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Additional States Issue Bulletins Prohibiting Cancellation for Nonpayment

March 30, 2020

In response to public health disaster emergency declarations for the novel coronavirus disease (COVID-19), some states issued bulletins which prohibit insurers from cancelling or nonrenewing policies for nonpayment of premiums. Recently, Proctor brought to your attention a statewide moratorium issued in Alaska. In addition, we would like to draw your attention to additional states that […]

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