As the COVID-19 pandemic evolves, states continue to take varying, responsive actions. These actions typically take the form of press release communications, guidance, regulations, and executive orders impacting regulated financial entities.
Hinshaw attorneys are working with clients daily to assist them in addressing issues that arise due to the COVID-19 crisis, including advising on notices to regulators, or actions or prohibitions relating to loan servicing or debt collection.
The Hinshaw Consumer Financial Services Team has developed the map below which contains information on three aspects of state action most relevant to consumer financial institutions:
- Regulator requirements – this category outlines specific requirements state financial institution regulators have imposed during the COVID-19 emergency, including guidelines for employees working from home;
- Limits on foreclosure and/or evictions – this category outlines prohibitions or limitations on financial entities related to foreclosure or eviction; and,
- Limits on debt collection – this category outlines prohibitions or limitations regarding collection of consumer debt during the COVID-19 emergency.
Click on a state to view the provisions applicable to that state. By clicking on the section title, you will be taken to the full agency provision referenced within the section.
- Blue states = Regulator requirements only
- Red states = Limits to foreclosure and/or evictions only
- Purple states = BOTH regulator requirements AND limits to foreclosures and/or evictions
- Green states = EITHER regulator requirements OR limits to foreclosures and/or evictions PLUS debt collection limitations
- Grey states = No applicable communications have been released
NOTE: This map does not contain the language of the actual agency communications, guidance, regulations, and orders. The language here has been paraphrased and summarized from the original source and is not a verbatim reference to the actual text. The map does not contain, and is not intended to provide, legal advice or establish an attorney-client relationship, and we recommend review of the actual language and status of each state's action. There may be local ordinances or municipal action on these topics which are not addressed in this map. While the map will continue to be updated, we cannot guarantee it is up to date as of the exact date it is accessed. Continued review on an ongoing, case-by-case basis, and consultation with counsel, is recommended. Please reach out to us if we can help you answer a state-specific question.
In addition to this map, visit Hinshaw's COVID-19 Resources Center to access other information related to COVID-19 response.
- Consumer and Class Action Defense
- Consumer Financial Services
- Mortgage Servicing and Lender Litigation
- Regulatory and Compliance Counseling