Guidance for California Financial Institutions Regarding COVID-19 Pandemic: California Business, Consumer Services and Housing Agency and California Department of Business Oversight Issue Guidance to Financial Institutions During the COVID-19 Pandemic

Sullivan & Cromwell LLP - March 25, 2020
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On March 22, 2020, the California Business, Consumer Services and Housing Agency (BCSH) and the California Department of Business Oversight (DBO) issued guidance to financial institutions regarding measures during the COVID-19 pandemic. Among other things, the DBO encourages such institutions to provide accommodations and alternative service options to customers. The DBO also stated that it will not criticize banks that hold virtual meetings, such as shareholder or Board meetings, without obtaining 100% shareholder consent or credit unions that hold virtual meetings in violation of their bylaws. The guidance makes clear that it does not modify any existing law or regulation.