Washington DFI Creates Resource Page for Managing Finances After a Natural Disaster
September 15, 2020
Recently the Washington State Department of Financial Institutions (DFI) created a resource page to help consumers handle their finances following a disaster. The page contains some steps to take and links to resources that may be of assistance. Credit unions may wish to share this information with their members. The following is based off the DFI resource, but has been updated with resources for all three states.
Steps to Take
- Report property damage to your property insurance company or agent as soon as possible. Don’t throw away damaged goods or make major repairs until a claims adjuster visits your residence. Keep receipts for emergency repairs.
- Look into disaster assistance. This may include special loans for homeowners, small business owners or farmers to use to repair or replace damaged property. Visit www.disasterassistance.gov to learn more. You can also call the Federal Emergency Management Agency at 1-800-621-FEMA (1-800-621-3362).
- Immediately contact your creditors if you don’t think you can pay your bills or make credit card or loan payments on time. Paying your debts late or not at all can result in penalties, interest charges, and damage to your credit score. Your creditors will likely work with you on a solution, but it’s important to contact them as soon as possible and explain your situation.
- Seek assistance from nonprofit organizations in your area. WA211.org can help connect you to local resources in your area. Local organizations can help you find temporary shelter, housing, food, and other support.
- Protecting and Rebuilding Your Finances After a Disaster
- Checklist: Rebuilding Your Finances
- What You Should Do In The Days Following A Disaster
Mortgages and Homes
- What Should I Do If My House Is Destroyed?
- Assistance for Homeowners Impacted by Disasters
- What Should I Know About Using Contractors After A Disaster?
- Handling Insurance Issues Following A Disaster
- Wildfire Insurance Resources
- Post-Disaster Claims Guide
Emergency Shelter and Housing
- Red Cross Shelters
- Idaho Animal Shelters Locations, Oregon Humane Society, Washington State Animal Emergency Shelters
Question of the Week
Q. When can we permit a member to waive their right of rescission for a loan secured by the member’s principal dwelling?
A. Right of rescission is almost never waived. For the right of rescission to be waived, the member must have a “bona fide personal financial emergency that must be met before the end of the rescission period.” This law is interpreted very strictly, so it does require an actual emergency situation to qualify. The member’s desire to finish up the paperwork as quickly as possible is not an emergency under this rule.
If there is a bona fide personal emergency, the credit union must receive a dated, written statement that describes the emergency, specifically modifies or waives the right to rescind, and bears the signature of all the consumers that are entitled to rescind.
Note that the Consumer Financial Protection Bureau has issued an Interpretative Rule to allow consumers to waive the rescission period due to circumstances caused by COVID-19. Specifically, the Bureau has stated:
The Bureau concludes in this interpretive rule that if a consumer determines that his or her need to obtain funds due to the COVID-19 pandemic (1) necessitates consummating the credit transaction before the end of the TRID Rule waiting periods or (2) must be met before the end of the Regulation Z Rescission Rules waiting period, then the consumer has a bona fide personal financial emergency that would permit the consumer to utilize the modification and waiver provisions, subject to the applicable procedures set forth in the TRID Rule and Regulation Z Rescission Rules. The Bureau also concludes in this interpretive rule that the COVID-19 pandemic is a “changed circumstance” for purposes of certain TRID Rule provisions, allowing creditors to use revised estimates reflecting changes in settlement charges for purposes of determining good faith. This interpretive rule will help expedite consumers’ access to credit under the TRID Rule and Regulation Z Rescission Rules.
For detailed information about how a member may exercise the waiver of the right of rescission during Covid-19 see the Bureau’s final rule.
National Credit Union Administration
NCUA Monitoring Wildfires in the Western States
The NCUA is tracking the wildfires in the western United States closely and stands ready to provide assistance to federally insured credit unions in the affected areas.
Washington Department of Financial Institutions
Handling Finances After a Natural Disaster
The DFI created a consumer resource page that provides some steps to take and links to resources that may be of assistance for consumers who may be facing challenges handling finances following a disaster.
Office of the Comptroller of the Currency
Credit Risk: Risk Management of Loan Purchase Activities
The OCC released OCC Bulletin 2020-81 to inform banks of sound risk management principles regarding loan purchase activities. While the bulletin is primarily for banks, credit unions may find the risk management guidelines helpful.
Financial Crimes Enforcement Network
FinCEN Issues Final Rule to Require Customer Identification Program, Anti-Money Laundering Program, and Beneficial Ownership Requirements for Banks Lacking a Federal Functional Regulator
FinCEN issued a final rule that requires minimum standards for anti-money laundering programs for banks lacking a Federal functional regulator. Banks lacking a Federal functional regulator will have 180 days from the day the final rule is published in the Federal Register to be in compliance.
Office of Foreign Assets Control
OFAC has updated the SDN list as of Sept. 10. The last update prior to this was Sept. 8.