On June 11, 2020, the Small Business Administration and the U.S. Department of the Treasury released their latest guidance in the form of “Paycheck Protection Program –Revisions to First Interim Final Rule” (the Revised Interim Final Rule). This Revised Interim Final Rule amends the SBA’s initial interim final rule posted on April 2,…

On June 3, 2020, Congress passed the PPP Flexibility Act to loosen requirements for loan forgiveness for CARES Act Paycheck Protection Program (PPP) borrowers. The new forgiveness rules will allow borrowers to extend the period for spending the loan proceeds to 24 weeks from the date of disbursement, an increase from the eight-week period originally…

On May 22, the Small Business Administration and the Treasury Department released its latest guidance in the form of two interim final rules on loan forgiveness: “Business Loan Program Temporary Changes; Paycheck Protection Program –Requirements – Loan Forgiveness” and “Business Loan Program Temporary Changes; Paycheck Protection Program – SBA Loan Review Procedures…

On April 9, 2020, in further response to the economic effects of the Coronavirus Disease 2019 (COVID-19) pandemic, the Board of Governors of the Federal Reserve System took actions to pump an additional $2.3 trillion in liquidity into the U.S. credit and capital markets. According to the Federal Reserve, this new $2.3 trillion – which…

On Sunday night, March 22, 2020, the federal banking agencies (OCC, FDIC, NCUA, Federal Reserve), the Consumer Financial Protection Bureau and the State Conference of Bank Supervisors issued an Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working with Customers Affected by the Coronavirus.

The Guidance does two key things:

1. Short-term loan…

Welcome to Greenberg Traurig’s LIBOR Transition Newsletter, where we provide updates, analysis, and occasional commentary on the latest developments relating to the highly anticipated phasing-out of LIBOR at the end of 2021 – barely two years from now. Questions addressed in this issue: Why is LIBOR being phased out? What will be the immediate effect? …

Rule 15c2-12 of the Securities Exchange Act of 1934 (Rule 15c2-12) was adopted by the Securities and Exchange Commission (SEC) in 1989 to establish standards for the procurement and dissemination of disclosure documents by underwriters as a means of enhancing the accuracy and timeliness of disclosure to municipal securities investors. Previous amendments to Rule 15c2-12…

On Nov. 3, 2016, the Florida Supreme Court issued its long-awaited decision in Bartram v. U.S. Bank National Association, No. SC14-1265, 2016 WL 6538647 (Fla. Nov. 3, 2016), bringing much-needed clarity to the outstanding question of whether the dismissal of a mortgage foreclosure action more than five years after it was filed bars the lender…

Last week, the Ninth Circuit held, in Bourne Valley Court Trust v. Wells Fargo Bank, NA that Nevada’s super-lien priority statute, NRS § 116.310, prior to certain amendments enacted in 2015, was facially unconstitutional.

Nev. Rev. Stat. 116.3116 establishes that liens resulting from non-payment of homeowners’ association (HOA) have priority over other secured liens for …

The Federal Communications Commission (FCC) has proposed rules to implement a provision in the Bipartisan Budget Act of 2015 (Budget Act) that allows robocalls (i.e., calls made with an automatic telephone dialing system or calls with an artificial or prerecorded voice) to be used for the purpose of collecting a debt owed to or…