September 25, 2020 – This week the Federal Reserve Board updated its FAQs for the Main Street Lending Program, and a bill was introduced in the House of Representatives to reduce fraud regarding unemployment benefits under the CARES Act.

Regulatory Developments Relating to the Pandemic

On September 18, the Federal Reserve Board updated its frequently asked questions (FAQs) to clarify the Board and Department of Treasury's expectations regarding lender underwriting for the Main Street Lending Program. The revised FAQs emphasize that lender underwriting should look back to the borrower's pre-pandemic condition and forward to its post-pandemic prospects. The FAQs also clarify supervisory expectations for lenders originating Main Street loans.

Legislative Proposals

H.R. 8284: Pandemic Unemployment Assistance Integrity Act 

On September 17, Representative Gary Palmer (R-AL) introduced legislation that would require individuals seeking unemployment benefits under the CARES Act Pandemic Unemployment Assistance program to submit documentation verifying employment, with the aim of decreasing fraud. Currently, the unemployment insurance program only requires applicants to self-certify that they have lost income due to the COVID-19 pandemic. 

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