Wednesday, September 23, 2020

The CARES Act and Credit Reporting: What Credit Unions Need to Know

by Bill Maurer and Melissa Wrapp, Center of Excellence for Emerging Technology, Filene Research Institute - creating research, innovation and connections for credit unions

The Coronavirus Aid, Relief, and Economic Security (CARES) Act was enacted on March 27, 2020, to provide emergency relief to consumers and businesses suffering from the economic fallout of the COVID-19 pandemic. The CARES Act contains a section (Sec. 4021) specifically addressing the credit reporting consequences of the pandemic. Even with direct stimulus payments, increased unemployment benefits, and the Paycheck Protection Program, consumers are facing dire financial circumstances. The expiration of relief payments and enhanced unemployment protection on July 31 has only made their situation more precarious.

Section 4021 does not go nearly far enough. It places the entire burden on consumers. It does not include all forms of debt, including debt collection accounts (which includes 99% of medical debt on credit reports). It does not standardize credit reporting practices. And more.

Still, there are ways your credit union can help your members.

PROBLEM: Protections are not automatic.

Consumers are required to contact creditors to ask for an accommodation. They are also required to do so for all their accounts. Most don’t even know where to begin.

What your credit union can do:

  • Proactively contact your members to let them know how to ask for an accommodation from their creditors.
  • Remind them of the top five most likely creditors they should contact. You can either look for trends in your area or go for the most likely creditors that any member would have. Provide them a checklist: Mortgage; car loan; student loan; credit cards.
  • Provide phone numbers or websites to the national credit reporting agencies (NCRAs) so they can obtain their free credit reports.
  • Preserve the dignity of your members and don’t overrun your call centers! Instead, consider automatic loan deferments or online/mobile solutions for loan deferment requests.

PROBLEM: Only deals with active accounts.

The CARES Act only deals with active credit accounts, not debt collection accounts like medical debt or debt owed to collection agencies employed by former landlords.

What your credit union can do:

  • Target small-dollar lending products to utility delinquencies, medical debt, or other debt collection accounts.
  • Help members identify court records of evictions and petition the court to have them expunged or sealed. The easiest way is to look at the Public Records section of their credit reports. They can also look up records on line via the National Center on State Courts website or partner with a third-party provider like MyRentalHistoryReport.Com (which charges a $29.95 fee). Or, identify and partner with a local nonprofit legal aid foundation.
  • Provide a dated letter of reference to members with eviction records indicating they are a member in good standing of your credit union that they can share with potential landlords when filling out a rental application.

PROBLEM: Consistency using the AW code.

Furnishers are not consistently using the AW code (“natural disaster”) in providing data about COVID-related delinquencies.

What your credit union can do:

  • Demand from NCRAs that furnishers of credit data use the AW code or CP (“short term forbearance”) in any data they provide to NCRAs.
  • Lobby Congress for consistent application of Metro 2 ® codes related to natural disasters, including pandemics. Make this an immediate and high priority for our trade groups.

PROBLEM: Student loans.

75% of forbearances are for student loans.

What your credit union can do:

  • Reach out to student borrowers and others with student loans to discuss their options. Identify them through your student loan providers/servicers; or, look for student loan payments in ACH files.
  • Ask your student loan providers/services to advertise the benefits provided in the CARES Act for student borrowers.

PROBLEM: Poor understanding of credit reports.

Consumers poorly understand their credit reports. The 3 NCRAs are currently providing weekly free reports during the pandemic.

What your credit union can do:

  • Make your members aware of the NCRAs free reports.
  • Provide educational materials for members on their credit reports, how to read them, the importance of their credit score, and how to improve their credit score. Direct them to the websites of the NCRAs or the CFPB, which has a handy primer on credit scores.


For full original post, additional resources, and detailed specifications from the CARES Act, go to:



Important Note
At the time the guide was prepared (August 2020), the second major stimulus and relief act has passed the House of Representatives, but negotiations are stalled between the House, Senate, and Trump administration. The House bill, called the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES) Act, replaces section 4021 of the CARES Act and provides a couple of important additional protections. Most significantly, it bans reporting medical debt related to COVID-19 treatment. This is a step in the right direction, but many individuals will suffer medical debts unrelated to COVID-19 treatment that they will still struggle to repay given the economic fallout from the crisis. It also forbids the use of alternative credit scoring models that “would identify a significant percentage of consumers as being less creditworthy when compared to the previous credit scoring models.”


Monday, September 14, 2020

Money and Speculation in Times of Crisis

by Smoki Musaraj. Ohio University

During the peak of the COVID-19 pandemic in Italy earlier this year, I frequently checked the Facebook feed of many friends and family living there. Growing up in Albania like me, many of them had migrated to Italy in the 1990s. I checked to make sure they were OK. Other friends situated in other parts of the world did the same. Facebook feeds became a space for comparing the degrees of quarantine in different countries and for providing mutual support in times of collective isolation. During these checks, I often ran into conversations by Albanian diaspora that compared the experience of the COVID-19 quarantines to that of the infamous year 1997 (or, in colloquial Albanian, nëntdhteshtata, the ninety-seven). This was a year of political anarchy, of a state of emergency, closed borders, of curfews and protests caused not by a virus but by the collapse of a dozen pyramid schemes. For many of my friends who had come of age in late-1990s Albania, the COVID times brought back the memory of social isolation and economic insecurity they experienced when the schemes collapsed.

My book, Tales from Albarado: Ponzi Logics of Accumulation in Postsocialist Albania (Cornell 2020), takes an ethnographic approach to the rise and fall of the dozen of pyramid firms (firma piramidale). The firms emerged alongside the free-market reforms and post-communist financial institutions that followed the demise of the communist regime. When the pyramid firms folded in 1997, the country unraveled into anarchy and a near civil war. Looking into newspaper archives and interviews with former investors, Tales from Albarado seeks to gain a better understanding of how people from various paths of life came to invest in the financial schemes and, in turn, how such schemes intertwined with everyday transactions, dreams, and aspirations. Through this ethnography of the Ponzi schemes in Albania, the book explores more broadly the materialities, socialities, and temporalities of financial speculation.

I served as postdoctoral fellow at IMTFI during 2012-2014. During these years, I revised the manuscript of Tales from Albarado while working alongside IMTFI fellows from different parts of the world who were also exploring questions about money and technology in the global South. My work with IMTFI and a wonderful group of fellows influenced my thinking about the various top-down and bottom-up financial repertoires mobilized by the pyramid firms in Albania. I began to think about the pyramid firms alongside many other financial enterprises that serve the unbanked and perform many of the financial functions that we associate with the formal banking sector. Given the history of a strict ban on private property during the communist period, many Albanians lacked assets and savings and they were quickly excluded from formal institutions during the 1990s, a time of free-market reforms and widespread privatization. Many of them turned to the pyramid firms as a means of saving, borrowing, and investing. I therefore situate the pyramid firms at the interstices of formal and informal economic institutions and repertoires that emerged alongside post-communist reforms. I argue that these institutions persist to this day.

"The Pyramid" by Like Rehova, Revista Klan, 2.11.1997, Vol 1 (1): 2.
Courtesy of the New York Public Library. 

Scholarly discussions of financial bubbles often focus on the abstraction and anonymity of capital as the fuel of speculation. In Tales from Albarado, by contrast, I emphasize the materialities and socialities of speculation. I do so by looking at the circulation and conversions of various things—stack of cash, privatization vouchers, remittances, housing—through the pyramid firms. These materialities, I argue, are entangled with specific economic and social histories and cultural norms. This approach resonates with the work of so many IMTFI fellows who research the old and new financial technologies and repertoires used by people living at the margins of global capital (Maurer, Musaraj, and Small 2018). Like many IMTFI projects, Tales from Albarado explores how financial activities are deeply intertwined with social ties. 

Thus, a key finding in Tales from Albarado pertains to the role of a widespread bottom-up economic repertoire: remittances. Remittances were sent to Albanian residents via transnational kinship networks. They were mostly in cash and in multiple currencies as this was a time before the euro. Drachmas, liras, marks, dollars featured prominently in recollections of former investors who often expressed pleasure in dealing in multiple currencies and in carrying stacks and sacs of cash to and from the firms. Cash enabled bundling deposits from multiple investors; multiple currencies enabled cultural cachet and opportunities for arbitrage; social ties of kin, friends, and brokers (sekserĂ«) enabled the expansion of investments to the firms. Accounts by former investors point to the highly personalized transactions that enabled financial speculation. Further, they provide a picture of a bottom-up repertoire—an informal cash economy in multiple currencies mediated by social ties—that constitute an enduring strategy of accumulation in a context of ongoing economic uncertainty. 

In addition to seeking other means of making wealth, I explore how participation in the pyramid firms entailed a negotiation of the temporalities of life and finance. The book looks into the buying, selling, and desiring of homes in conjunction with participating at the pyramid firms. A number of investors sold their recently privatized apartments (formerly state-owned) in order to invest at the firms. At the same time, most investors I interviewed, when asked what they planned to do with their returns, expressed their desire to buy a new home. The new homes were often imagined as an accelerated path towards a capitalist and European modernity. Those who had lost their homes to the schemes lamented their “lagging behind” this imagined trajectory. Housing, thus, became a site for materializing such temporal aspirations and for witnessing their failure. 

By examining the materialities, socialities, and temporalities of the speculative schemes, Tales from Albarado identifies economic practices and institutions as well as desires and aspirations that have endured throughout the three decades of neoliberal transformations in Albania. Strategies of value conversion, a propensity for accessing multiple regimes of value, intertwining finance and social ties, desires for an accelerated European modernity—these are all well-established social and financial institutions that make up the economic and social life in Albania. They are also practices and institutions that mirror the experiences of myriads of people whose lives are shaped by similar forms of geopolitical marginality and economic instability. These intertwined economies and socialities in contemporary Albania thus speak more broadly to the making of neoliberal economies at the margins.


References

Maurer, Bill, Musaraj, Smoki and Small, Ivan V. eds., 2018. Money at the Margins: Global Perspectives on Technology, Financial Inclusion, and Design. Berghahn Books.


Smoki Musaraj is associate professor of anthropology and director of the Center for Law, Justice, and Culture at Ohio University. 


Friday, September 4, 2020

GovExec Daily: Physical Cash and the Pandemic

Dr. Bill Maurer of University of California, Irvine joins the Government Executive Daily podcast  by Adam Butler and Ross Gianfortune to discuss what cashless payments look like, in light of the pandemic.


Access GovExec Daily: Physical Cash and the Pandemic





With the COVID-19 cases spiking and online shopping following, the argument for ending physical money has come up again in the public conversation. But, a cashless existence is not our reality yet. 

Bill Maurer is dean of University of California, Irvine's School of Social Sciences, a professor of anthropology and director of the campus’s Institute for Money, Technology & Financial Inclusion (IMTFI). He joined the show to examine why the conversation about the end of physical cash is probably premature, even during the pandemic