Troutman Pepper Hamilton Sanders
21 June 2021
Like most industries today, Consumer Finance Services businesses
are being significantly impacted by the novel coronavirus
(COVID-19). Troutman Pepper has developed a dedicated
COVID-19 Resource Center to guide clients through this
unprecedented global health challenge. We regularly update this
site with COVID-19 news and developments, recommendations from
leading health organizations, and tools that businesses can use
free of charge.
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Our bank and loan servicing clients also face novel challenges
affecting their industry due to COVID-19, particularly the
ever-changing rules and regulations concerning evictions and
foreclosures. We closely track these updates and have assembled an
interactive tracker containing state orders and guidance documents
regarding residential foreclosure and eviction moratoriums. You may
access this interactive tool at
To help you keep abreast of relevant activities, below find a
breakdown of some of the biggest COVID-19 driven events at the
federal and state levels to impact the Consumer Finance Services
industry this past week:
On June 10, President Joe Biden announced that the United
States plans to donate 500 million Pfizer COVID-19 vaccine doses
globally as part of his efforts to reassert U.S. leadership on the
world stage. The move also will serve to counter efforts by Russia
and China to use their own state-funded vaccines to expand their
global influence. For more information, click here.
On June 9, the Occupational Safety and Health Administration
(OSHA) released its long anticipated interim final rule and request
for comments for the Occupational Exposure to COVID-19;
Emergency Temporary Standard (ETS). The ETS is limited to
covered health care employers and excludes from coverage certain
health care workplaces that have a fully vaccinated workforces and
that exclude individuals with possible COVID-19 infections. The
rule becomes effective on the date of publication in the
Federal Register with deadlines for compliance that vary
by section of the ETS. For more information, click here.
On June 11, Connecticut Attorney General William Tong and D.C.
Attorney General Karl Racine led a coalition of 23 attorneys
general to file a brief with the Supreme Court, supporting the
Centers for Disease Control and Prevention’s (CDC) order that
prohibits evictions during the COVID-19 pandemic. “Lifting of
this stay would trigger a disastrous wave of sudden evictions
across the country and in Connecticut. It would be highly unusual
for the Supreme Court to step in at this juncture. The CDC order is
lawful, necessary to protect public health, and must remain in
place,” said Attorney General Tong. For more information,
On June 8, California Attorney General Rob Bonta warned
“financial institutions, creditors and debt collectors that it
is illegal to seize federal Child Tax Credit payments for
individual debts in California.” In his statement, Attorney
General Bonta reminded financial institutions that Governor
Newsom’s April 23, 2020 executive order makes any such
garnishment unlawful as it is financial assistance provided due to
the COVID-19 pandemic. For more information, click here.
The Idaho Department of Finance is expected to extend its
temporary guidance through December 31, 2021, allowing remote work
without a branch license. Licensees must still comply with security
requirements enumerated in the original guidance. For more
information, click here.
On June 11, Troutman Pepper released a brief overview of
President Biden’s executive order (EO) signed on May 12.
“This EO calls on both the federal government and the private
sector to identify, deter, detect, and respond to cyber
incidents.” The EO appears to respond to the significant rise
of cyberattacks from cybercriminals, potentially relating to the
increased remote workforce due to COVID-19. A major takeaway
includes that the “EO should remind all companies [to] assess
their information security program and practices” because the
Biden administration may update and adopt additional security
practices moving forward. To learn about other notable EO
requirements, click here.
On June 8, the Massachusetts attorney general’s office
released a report, detailing the rise of ransomware attacks and
stressing the importance of protecting data. The COVID-19 pandemic
has increased the risk of ransomware for many organizations, such
as hospitals, governments, and universities. The report warned that
“[a]ll organizations, regardless of sector, size, or location,
must recognize that no company is safe from being targeted by
ransomware,” and Attorney General Maura Healy “strongly
encourage[d] all Massachusetts business and government
organizations to take the appropriate steps to strengthen data
security and ensure its computer networks are secure as required by
law.” To view the list of safeguards recommended by the
AG’s office and for a link to the Massachusetts Data Security
Regulations, click here.
On June 7, it was reported that as California reaches nearly 40
million individuals vaccinated as a result of the state’s cash
incentive program, “the flood of corresponding medical
information is sparking fresh privacy concerns about
Californians’ health data.” These concerns arise from the
increased proliferation among nonclinical entities, such as
employers, pharmacies, community-based health organizations, and
telehealth providers of medical patient data across third-party
platforms. Also, these concerns are coupled with updates to
confidentiality laws, such as the federal Health Insurance
Portability and Accountability Act (HIPPA) – for instance,
emergency waivers to make protected information available to fight
the pandemic. The emergence of vaccination verification systems
linking vaccinated patients’ health statuses and identities has
sparked debates around the efficacy of the systems’ design,
implementation, and confidentiality. For those interested in
learning more, click here.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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