January 21, 2021 

Parson Announces Mass Vaccination Sites Across Missouri

Gov. Mike Parson announced Wednesday that the Missouri National Guard will begin assisting the Missouri Department of Health and Senior Services and other state partners in establishing COVID-19 vaccination sites across the state.

A mass vaccination team will be assigned to each of Missouri's nine Highway Patrol regions to assist in establishing and staffing mass vaccination and targeted vaccination sites. A mass vaccination site is scheduled to begin this week in southeastern Missouri, and other sites will be operational in the remaining eight Highway Patrol regions by the end of January. These sites have the capability to provide up to 2,500 doses per day, per team. More details concerning dates and locations will be released once finalized.

Visit MoStopsCOVID.com to view the latest vaccine updates, find out when you are eligible for the vaccine and locate available vaccinators in your area.  

Bank Economists Anticipate Strongest Growth In 20 Years In 2021

While the economy remains under the influence of the COVID-19 pandemic, the nation’s top bank economists expect the U.S. economy in 2021 to see its strongest growth in about 20 years. ABA’s Economic Advisory Committee, which is made up of 15 chief economists from some of the nation’s largest banks, noted that it expects the economy to grow at a 4% rate this year, although growth is expected to be slow in the first quarter.

“The painful toll from COVID-19 continues to add up,” said EAC Chair Beata Caranci, chief economist at TD Bank Group. “In addition to rising hospitalizations and deaths, the pandemic is weighing on the U.S. economy as social distancing and business shutdowns in many states have slowed commerce considerably.” 

She added that economic growth should accelerate as the balance begins to shift from hospitalizations to vaccinations.

The committee said it expects little change in short-term interest rates in 2021 and projected that rates on longer-term U.S. Treasury securities and mortgage rates will rise modestly. The unemployment rate is projected to decline from December’s rate of 6.7% to 5.4% by the end of the year. 

“The pandemic has pushed many companies to be more efficient and that has accelerated trends in digitization and that in turn may reduce the speed in rehiring,” Caranci said.

Agencies Issue Final Rules Clarifying Role Of Supervisory Guidance

The Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the Consumer Financial Protection Bureau each issued final rules (FDIC, OCC, CFPB) codifying that regulatory guidance does not have the force and effect of law, granting much of a joint petition filed by the American Bankers Association and the Bank Policy Institute that sought a formal rulemaking to ensure that banking organizations would not need to rely on a 2018 interagency statement to clarify the role of guidance.

The agencies confirmed in the final rule that they do not “take enforcement actions or issue supervisory criticisms based on non-compliance with supervisory guidance. Rather, supervisory guidance outlines supervisory expectations and priorities, or articulates views regarding appropriate practices for a given subject area.” Meanwhile, regulations do have the force and effect of law and enforcement actions can be taken if regulated institutions are in violation. Regulations also are generally required to go through the notice and comment process.

The agencies are adopting the final rule on an agency-by-agency basis, rather than pursue a joint final rulemaking, noting that “having separate final rules has enabled agencies to better focus on explaining any agency-specific issues to their respective audiences of supervised institutions and agency employees.” The Federal Reserve is expected to adopt a similar rule in the near future.

IRS Publishes Information Reporting Guidance On SBA, Other Subsidies

The Internal Revenue Service issued guidance addressing various tax information reporting issues that arose as a result of taxpayer subsidies included in the CARES Act and the more recent COVID-19 relief bill. In general, the notice confirms that information returns (such as the 1099-MISC, 1099-C, etc.) are not required for recipients of loan forgiveness or other subsidized payments.

Importantly, the notice addresses reporting issues raised by a prior Small Business Administration notice that required the issuance of Form 1099-MISC and Form 1098 to report 7(a) loan subsidies as income and subsidized expenses (mortgage interest) as interest paid.

The guidance provides that original and second-round PPP forgiveness, emergency financial aid grants for students, Treasury program loan forgiveness, EIDL grants, loan subsidies and shuttered venue operator grants are not considered reportable income. However, the notices does allow for reporting subsidized mortgage interest on Form 1098. 

FHFA Extends Loan Processing Flexibilities For GSEs Through February

To continue providing support to mortgage borrowers during the coronavirus pandemic, the Federal Housing Finance Agency said it would extend through Feb. 28 certain previously announced loan processing flexibilities.

These flexibilities, which were set to expire Jan. 31, include allowing alternative appraisals on purchase and rate term refinance loans, alternative methods for documenting income and verifying employment before loan closing and expanding the use of power of attorney and remote online notarizations to assist with loan closings. 

FHFA Extends Foreclosure, Eviction Moratoriums Through Feb. 28

The Federal Housing Finance Agency announced it would extend through Feb. 28 a moratorium on foreclosures and real estate owned evictions for single-family mortgages backed by Fannie Mae or Freddie Mac. The current moratorium was set to expire Jan. 31.

FHFA To Allow GSEs To Retain Earnings To Build Capital 

As part of the ongoing effort to remove Fannie Mae and Freddie Mac from government conservatorship, the Federal Housing Finance Agency and the Treasury Department announced it would allow the GSEs to retain earnings until they meet the capital requirements established in the 2020 GSE capital rule. Treasury also said that Fannie and Freddie may raise private capital and leave conservatorship once certain conditions are met.

In letter agreements with each GSE, FHFA and Treasury said they would work “to restructure Treasury’s investment and dividend in a manner that facilitates the orderly exist from conservatorship, ensures Treasury is appropriately compensated, and permits the enterprise[s] to raise third-party capital as appropriate,” and that they should aim to put a proposal before Congress addressing these matters before Sept. 30.

FHFA Issues RFI On Managing Climate, Natural Disaster Risk

The Federal Housing Finance Agency issued a request for information seeking feedback on how climate change and natural disasters could pose risks to the housing finance system, Fannie Mae and Freddie Mac and the Federal Home Loan Banks.

The RFI poses a series of questions focused on identifying and assessing climate and natural disaster risk and enhancing FHFA’s supervisory and regulatory framework in this area. Comments on the RFI are due by April 19.

CFPB Finalizes Exemption From Escrow Requirements For HPMLs 

The Consumer Financial Protection Bureau finalized a rule exempting certain higher-priced mortgage loans from a requirement under Regulation Z to establish escrow accounts for those loans, as required by the S. 2155 regulatory reform law. The rule takes effect upon publication in the Federal Register and provides a transition period of 120 days.

Under the final rule, HPMLs made by an insured depository institution would be exempt from the Reg Z escrow requirement if the institution had assets of $10 billion or less, if the institution and its affiliates originated 1,000 or fewer loans secured by a first lien on a principal dwelling during the preceding calendar year and if certain other criteria are met.

CFPB Publishes Small Entity Compliance Guide On Debt Collection Rule

The Consumer Financial Protection Bureau has issued a small entity compliance guide summarizing its debt collection rule issued in October 2020. The final rule modernized and clarified existing rules regarding third-party debt collection. 

Kraninger Resigns As CFPB Director

Consumer Financial Protection Bureau Director Kathy Kraninger announced her resignation as head of the agency. Kraninger was tapped to lead the CFPB in 2018 by former President Trump. Nominally appointed to a five-year term, the CFPB director was held by the Supreme Court in 2020 to be removable at the pleasure of the president.

President Biden over the weekend said he intends to nominate Rohit Chopra, a Democratic member of the Federal Trade Commission who was a member of the launch team for the CFPB, as the bureau’s next director. In the meantime, Biden designated Dave Uejio, the CFPB’s chief strategy officer, as acting director.

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