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The CFPB has released two templates under its No-Action Letter (NAL) Policy to assist entities looking to provide consumers with relief amid the coronavirus pandemic: One of the templates is for mortgage servicers and the other is for small-dollar lenders.

The NAL template for mortgage servicers allows them to apply for an NAL to use an online platform to implement loss-mitigation efforts for their borrowers in an attempt to avoid foreclosure. Brace Software, Inc., submitted the application for the template for its online version of Fannie Mae's Form 710 – the loss mitigation application used by most mortgage servicers.

"While the Bureau does not endorse particular products or providers, digitizing the loss mitigation application process has the potential to improve a process that is experiencing an increase in loss mitigation requests from consumers due to the COVID-19 pandemic," the bureau said in a release.

As the financial regulators encourage financial institutions to offer safe small-dollar lending options to consumers facing financial hardship amid the pandemic, the second NAL template can be used by insured depository institutions to apply for a NAL covering their small-dollar credit products. The template, applied for by the Bank Policy Institute, also includes important protections for consumers seeking small-dollar loan products.

Relatedly, the CFPB is expected to soon release a new rule related to payday lending in an attempt to provide more clarity. NAFCU has previously called on the bureau to extend its safe harbor under the rule to include all future payday alternative loans (PALs) products following the NCUA's expansion of its PALs program. Members of NAFCU's Government Affairs team met with the CFPB in December to discuss the bureau's ongoing rulemaking efforts, including payday lending, and to share credit unions' perspectives.

In September, the bureau issued the NAL Policy, Trial Disclosure Program Policy, and Compliance Assistance Sandbox (CAS) Policy. NAFCU is supportive of the bureau's efforts to promote innovation and facilitate compliance at financial institutions and will keep credit unions informed of additional templates that could enhance their operations.