COVID-19 Impact

Below is a list of states where debt collection activities are wholly or partially prohibited by emergency guidance from state regulators.

Massachusetts

• Temporary Restraining Order: Collectors Allowed to Phone Consumers in Massachusetts (5/6)
• Attorney General: Emergency Assistance Provided Pursuant to The Cares Act Is Exempt from Seizure by Creditors and Debt Collectors (4/13/2020)
• Attorney General: Emergency Debt Collection Regs banning legal enforcement of debt and outbound collection telephone calls (3/27/2020)
• Governor: Executive Order Closing Non-Essential Businesses, and Exhibit A to Executive Order, List of Essential Services (3/23/3030)
• Div. of Banks: Email re Business Continuity Plans, Permitting Licensed Mortgage Loan Originators to WFH (3/11/2020)

Nevada

• Dep’t of Business and Industry, Fin. Institutions Div.: Collection Agencies Deemed Non-Essential Businesses (3/20/2020)
• Governor: Announcement of Closure of Non-Essential Businesses (3/20/2020)
• Dep’t of Business and Industry, Fin. Institutions Div.: Collection Agencies Deemed Non-Essential (3/18/2020)
• Clark County Court: Admin. Order Pushing All Non-Essential Matters 60 Days (3/16/2020)

New York

• Attorney General: Attorney General James and Governor Cuomo Temporarily Suspend State Debt Collection in Response to Coronavirus (3/17/2020)

North Carolina

• Dep't. of Insurance: Order Requiring Collectors to Provide Consumers Option to Defer Payments, per North Carolina General Statute § 58-2-46 (3/20/2020), requires collectors to provide payment deferral to consumers, but does not ban outbound collection efforts
• Attorney General: Suspension of Collections of State-Owned Debts (3/26/2020)

Washington, DC

• New Law Temporarily Banning Outbound Collections During COVID-19 Crisis (4/7/2020)

Joint

• Federal Agencies Encourage Banks, Savings Associations, and Credit Unions to Offer Responsible Small-Dollar Loans to Consumers and Small Businesses Affected by COVID-19 (3/26/2020)

Dep’t. of Labor

• Wage & Hour Division: Field Assistance Bulletin—Temporary Non-Enforcement Period Applicable to the Families First Coronavirus Response Act (FFCRA) (3/24/2020)
• Families First Coronavirus Response Act: Employer Paid Leave Requirements
• Families First Coronavirus Response Act Notice – Frequently Asked Questions
• Wage & Hour Division: COVID-19 and the American Workplace
• Coronavirus Resources

CFPB

• Statement on Supervisory and Enforcement Practices Regarding the Fair Credit Reporting Act and Regulation V in Light of the CARES Act (4/1/2020)
  
• CFPB Provides Flexibility During COVID-19 Pandemic (3/26/2020)
• Resources for Consumers During COVID-19 Pandemic (3/24/2020)

FTC

• FTC Chairman Joe Simons Outlines the Agency’s Approach to Safeguarding Consumers during the Coronavirus Pandemic (3/26/2020)
• Avoid Coronavirus Scams

U.S. Small Business Association

• Paycheck Protection Program (PPP)
• Paycheck Protection Program Sample Application
• Paycheck Protection Program Information Sheet

Cybersecurity & Infrastructure Security Agency

• Identifying Critical Infrastructure During COVID-19
  

IRS (Internal Revenue Service)

• Employee Retention Credit available for many businesses financially impacted by COVID-19 (3/31/2020)
  
• People First Initiative (3/25/2020)
• Letter from the Hon. John Lewis, Chair of the Subcommittee on Oversight, Suggesting a Cease of Private Debt Collection for the IRS (3/25/2020)

Arizona

• Governor: Executive Order Clarifying Essential Businesses (3/23/2020)

California

• Proposal to Mayor of Los Angeles: Declare Collection Agencies Non-Essential and Not Allow Debt Collection During the State of Emergency ( dated 4/7/2020 -- for LOS ANGELES only, and this is still only a proposal)
• Executive Dept State of California: CA executive order protecting stimulus checks from garnishment (4/23/2020)

Colorado

• Governor: Amending and Extending Executive Order D 2020 017 Ordering Coloradans to Stay at Home Due to the Presence of COVID-19 (4/6/2020)

Connecticut

• Dep't. of Banking: Extends their no-action position for collectors working from home until August 31 (6/19/2020)
• Dep’t. of Banking: No Action Position Regarding Temporarily Working from Home Due to COVID-19 (3/9/2020)

Florida

• Governor Executive Order: Stay at Home Order (3/23/2020)
• Governor Executive Order: Essential & Nonessential Businesses
• Miami-Dade County Mayor: Emergency Order Closing Non-Essential Businesses (3/19/2020)

Hawaii

• Governor: Stay-at-Home Order, Closing Non-Essential Businesses (3/23/2020)

Idaho

• Dep’t. of Fin.: Temporary Regulatory Guidance Regarding Working from Home Due to Coronavirus/COVID-10 Concerns or Quarantines (3/12/2020)

Illinois

• Executive Department: Illinois exempts stimulus checks from garnishment (4/14/2020)
• Dept. of Fin. and Professional Regulation: Guidance to Illinois-Licensed Debt Collection Agencies and Debt Buyers Regarding COVID-19 (3/30/2020)
  
• Illinois Department of Financial and Professional Regulation: IDFPR guidance for state banks and credit unions and help for their consumers (3/30/2020)
  
• Illinois Department of Financial and Professional Regulation: Guidance to Illinois-Licensed Student Loan Servicers Regarding Federal Student Loan Interest Waivers and Administrative Forbearances and COVID-19 (3/30/2020)
  
• Secretary of State: Remote Working for a Loan Broker/Collection Agency in Response to COVID-19 Outbreak (3/24/2020)
• Governor's Notice: Executive Order in Response to COVID-19 (3/20/2020)
• City of Chicago Dep’t. of Business Affairs and Consumer Protection: BACP Offices Closed - Effective 3/19/2020 (3/18/2020)

Indiana

• Indiana Supreme Court: Indiana Supreme Court order staying garnishments of stimulus checks (4/20)
• State of Indiana Executive Dept.: Renewal of Public Health Emergency Declaration for COVID-19 Outbreak (4/3/2020)

Maine

• Governor: An Order Regarding Further Restrictions on Public Contact and Movement, Schools, Vehicle Travel and Retail Business Operations (Corrected) (3/31/2020)
• Governor: An Order Regarding Essential Business and Operations (3/24/2020)
  

Maryland

• Maryland State Collection Agency Licensing Board: Guidance for Collection Agencies Ceasing Activities (5/11/2020)
• Office of Legal Counsel: Interpretive Guidance of Governor’s Order to Close All Non-Essential Businesses (3/23/2020)

Massachusetts

• Temporary Restraining Order: Collectors Allowed to Phone Consumers in Massachusetts (5/6)
• Attorney General: Emergency Assistance Provided Pursuant to The Cares Act Is Exempt from Seizure by Creditors and Debt Collectors (4/13/2020)
  
• Attorney General: FAQ Concerning 940 CMR 35.00 (4/4/2020)
• Governor: Order Extending the Closing of Certain Workplaces and the Prohibition on Gatherings of More Than 10 People (3/31/2020)
• Attorney General: Emergency Debt Collection Regs (3/27/2020)
• Governor: Executive Order Closing Non-Essential Businesses, and Exhibit A to Executive Order, List of Essential Services (3/23/3030)
• Div. of Banks: Email re Business Continuity Plans, Permitting Licensed Mortgage Loan Originators to WFH (3/11/2020)
• State Website: Information on the Outbreak of Coronavirus Disease 2019 (COVID-19)
  

Minnesota

• Minnesota Commerce Dept.: Enforcement Guidance regarding Minnesota Statutes §332.33, subd. 3 (WFH) (5/15/2020)
• Governor: Protecting Emergency Government Support from Consumer Garnishment (5/4/2020)
• Commerce Department: Collectors May Work from Home During Quarantine (4/24/2020)
• Governor: Executive Order to Stay-at-Home, Close Non-Essential Businesses (3/27/2020)
• Governor: Critical Sector Descriptions, Clarifying Debt Collection Agencies are Not Exempt from Stay-at-Home Order (3/27/2020)
• Minnesota Commerce Dept.: Enforcement Guidance regarding Minnesota Statutes § 332.33, subd. 3 (3/13/2020)

Mississippi

• Governor: Shelter in Place Order (4/1/2020)
• Governor: Essential Businesses Executive Order 1463 (4/1/2020)

Nevada

• Dep’t of Business and Industry, Fin. Institutions Div.: Collection Agencies Deemed Non-Essential Businesses (3/20/2020)
• Governor: Announcement of Closure of Non-Essential Businesses (3/20/2020)
• Dep’t of Business and Industry, Fin. Institutions Div.: Collection Agencies Deemed Non-Essential (3/18/2020)
• Clark County Court: Admin. Order Pushing All Non-Essential Matters 60 Days (3/16/2020)

New Mexico

• Financial Institutions Div.: Guidance re Non-Essential Businesses (3/24/2020)
• Commerce Dep’t.: Temporary Guidance to Allow Collectors to WFH w/o Licensing Branch Office (3/13/2020)

New York

• NYC Introduces COVID-19 Relief Package: Tenants Get Relief from Evictions and Paying Late Rent (4/29/2020)
  

North Carolina

• Department of Insurance: NC Dept of Insurance extends order re payment deferral options (4/21/2020)
• Department of Insurance: North Carolina Dept of Insurance FAQ Associated with the Commissioner's Order and Bulletin 20-B-06
• Department of Insurance: Licensing Guidance from State Agencies in Response to Coronavirus (Amended) (3/30/2020)
• Governor Executive Order: Stay at Home Order and Strategic Directions for North Carolina in Response to Increasing COVID-19 Cases (3/27/2020)
• Department of Insurance: Order Requiring Collectors to Provide Consumers Option to Defer Payments, per North Carolina General Statute § 58-2-46 (3/27/2020)
• North Carolina General Statute § 58-2-46 
  
• Attorney General: Suspension of Collections of State-Owned Debts (3/26/2020)

Ohio

• Dept. of Health: Stay at Home Order (3/23/2020)
• Governor: Executive Order 2020-01D State of Emergency Declaration (3/9/2020)

Oklahoma

• Governor: Amended Executive Order Closing Businesses Not Critical Infrastructure (3/24/2020)

Oregon

• Governor: Oregon exempts stimulus checks from garnishment (4/17/2020)
• Div. of Fin. Reg.: Temporary Work from Home (3/12/2020)

Pennsylvania

• Governor: PA extends stay at home order to May 8
• Governor: Updated Stay-at-Home Order (3/28/2020)
• Governor: Closure of Non-Life Sustaining Businesses and List of Life-Sustaining Businesses (3/19/2020)

Rhode Island

• Attorney General: Payments Provided Pursuant to the CARES Act are Exempt from Seizure by Creditors and Debt Collectors (4/28/2020) 

South Carolina

• Governor: Executive Order Closing Non-Essential Businesses (3/31/2020)

Tennessee

• Governor: An Order Directing Tennesseans to Stay Home Unless Engaging in Essential Activities to Limit Their Exposure to and Spread of COVID-19 (3/30/2020)
  

Washington

• Washington Collection Agency Board: Removes work at home agents from the definition of branch office (6/18/2020)
  
• Governor: Washington State exempts stimulus checks from garnishment (4/14/2020)
• Governor: Stay-at-Home Order Closing Non-Essential Businesses (3/23/2020)

Washington, DC

• New Law Temporarily Banning Outbound Collections During COVID-19 Crisis (4/7/2020)

West Virginia

• Governor: Debt Collectors Considered Essential Business (3/23/2020)

Wisconsin

• Governor: Stay-at-home order, list of essential businesses (3/24/2020)

If you have more up-to-date docs than the ones listed here, please send them to editor@insidearm.com.

Credit Reporting

• CDIA: Covid-19 Resources

Work From Home

• insideARM Research Assistant: Work From Home Policies & Procedures
• Cornerstone: May Collectors Work from Home in Response to Coronavirus Threat?

Licensing

• Cornerstone: Licensing Requirements During COVID-19

Mortgages

• NMLS: State Agency Communication/Guidance on Coronavirus/COVID-19

Additional Resource Pages

• ACA International: COVID-19 ACA Updates
• Ballard Spahr: Coronavirus Disease 2019 (COVID-19) Resource Center
• Brownstein Hyatt Farber Schreck: Insights on Coronavirus (CARES Act and SBA loan resources)
  
• Clark Hill: COVID-19 (Coronavirus) Resources
• CSBS (Conference of State Bank Supervisors): COVID-19 Consumer Resources
• Dinsmore: COVID-19 Business Strategies Hub
• Fastcase: COVID-19 Resources
• insideARM/Research Assistant: COVID-19 Questions, Answers, Resources
• Littler: Coronavirus (COVID-19) Resources for Employers
• Manatt: COVID-19
• National Center for State Courts: Coronavirus News Updates, Court Administrative Orders, and more Resources
• TransUnion: Consumer Financial Hardship Study
• Troutman Sanders/Pepper Hamilton: COVID-19 Resource Center
  

insideARM Webinars

• REGISTRATION OPEN: Leading Strategically Through the Recovery: Delivering Timely Customer Support in the Face of Rising Demand and Capacity Constraints, 5/6 @ 3.00 pm Eastern (insideARM)
• REGISTRATION OPEN: Leading Strategically Through the Recovery: The Role Crisis Can Play in Accelerating Innovation and Adoption, 5/13 @ 3.00 pm Eastern (insideARM)
• ON DEMAND: Leading Strategically Through the Recovery: The Industry Outlook (insideARM)

Upcoming COVID-19 Webinars

• REGISTRATION OPEN: Leading Strategically Through the Recovery: The Industry Outlook, 4/22 @ 1.00 pm Eastern (insideARM)
• REGISTRATION OPEN: Leading Strategically Through the Recovery: Delivering Timely Customer Support in the Face of Rising Demand and Capacity Constraints, 5/6 @ 3.00 pm Eastern (insideARM)
• REGISTRATION OPEN: Leading Strategically Through the Recovery: The Role Crisis Can Play in Accelerating Innovation and Adoption, 5/13 @ 3.00 pm Eastern (insideARM)

On-Demand Webinars

Labor & Employment

• Planning Ahead How to Handle Litigation Defense and Pre-Lit Claims During and After COVID-19 (insideARM)
  
• Ask Amy: Leading with Authenticity During a Crisis (insideARM)
  
• Practical Issues for Employers in Navigating the New Federal Emergency Paid FMLA and Sick Leave Mandates (Littler Mendelson) 
• COVID-19: Common Employer Questions Asked and Answered! (Littler Mendelson)

Ops/Risk Management

• Managing Coronavirus Operational Risk Department-by-Department: What You Need to Do Today (American Bankers Association)
• Small Business Roundtable Hosted a Web Event Featuring the Small Business Administration, U.S. Senate Small Business & Entrepreneurship Committee and Special Partners to Discuss COVID-19 Relief (SBA)
  

• Digital Payment Solutions to Maintain Business Continuity (PaymentVision)
  
• Top 4 Issues Collection Strategy Execs Must Consider Now: COVID-19 Edition (insideARM)
• Accounts Receivable Management | An Essential Part of the U.S. Economy (Kaulkin Ginsberg)