March 26, 2020
Since March 1, 2020, the Government Relations Committee has been engaged on a daily basis in
- responding to questions posed by members either through the NPA Office or directly to Fran Bishop as GRC Liaison,
- reviewing, preparing and issuing GRC Updates for all pawnbrokers on legislation pending in Congress to address issues related to pawnbrokers and pawn customers,
- responding for requests for help from state and local pawnbroker groups and individual pawnbrokers in persuading state and local governments that pawn stores are “essential businesses” that should be allowed to continue serving their communities to the same extent as banks, credit unions, and other non-depository providers of financial services,
- responding to requests from individual members for assistance in managing specific challenges and communicating with customers,
- working with members of Congress and staffs to see that pawnbrokers are designated as “essential businesses,” as providers of regulated “financial services,” and as “financial institutions,” and trying to keep all efforts to enact a temporary APR cap on consumer credit from happening. This temporary APR cap is a separate effort from the Federal Rate Cap bills we’ve been continually working since last November, and
- reviewing regulatory guidance from federal agencies—IRS, DOL, Treasury, interagency small dollar lending.
Among the most public endeavors that Team GRC has undertaken are the following GRC Updates and Legislative Alerts on recent federal legislation:
- Advance Alert on H.R. 6201 – the Phase 1 Relief Act – Division C (emergency paid sick leave and FLMA amendments) – March 17, 2020
- Advance Alert on H.R. 6201 – the Phase 1 Relief Act – Division E (longer-term paid sick leave and FMLA amendments) – March 17, 2020
- Updated Alert on H.R. 6201 Division C as enacted March 18, 2020 – March 20, 2020
- Updated Alert on H.R. 6201 Division E as enacted March 18, 2020 — March 20, 2020
- Alert on State Regulators’ Guidance to Licensees – March 17, 2020
- Alert on Preparing Stores and Employees for the COVID-19 Emergency – March 15, 2020
- Alert on Why Pawnbrokers Are Essential Businesses and “Financial Institutions” under Federal Law – March 18, 2020 – for members’ use in dealing with local governments and state regulators
Among the most public letters drafted by Team GRC for pawnbrokers to use if Local Governments Issue Closure Notices:
- New York State – assistance to CLANY and its NYS counsel on getting operating permission for the City of New York, and in securing operating permission from the state.
- Florida – March 23, 2020 letters to Governor DeSantis and the Florida Department of Agriculture (state regulator)
- City of Miami – 3/23/2020 letter to Mayor of Miami that resulted in his decision to include pawn stores in the “essential business” category – and requesting reversal of his original decision to close pawn stores.
- Alabama – ongoing assistance to Alabama Pawnbrokers Association for communications with Governor Ivey, and to City of Birmingham when the mayor did not designate pawn stores as essential.
- Puerto Rico – March 21, 2020 – letter to Governor and Superintendent of Commonwealth Police supporting designation of pawn stores as essential businesses and as “financial institutions.”
- Texas – March 24, 2020 letter to Governor Abbott regarding local decisions to exclude pawn stores from local closing declarations and request for assistance in explaining to local governments operating under home rule authority why state-licensed and supervised, non-depository providers such as pawnbrokers should be open to the same extent as other “financial institutions”.
- Houston, Texas – March 24, 2020 – work on request from local pawnbroker to clarify pawn stores’ inclusion in federal DHS coverage of essential services and what the financial services sector includes.
Comment: Team GRC stands ready to assist other pawnbrokers or groups of pawnbrokers in communicating with state and local officials about their operations as “financial institutions” and as “essential businesses.”
Fran’s list of detailed information, executive orders, emergency declarations, etc. from her contacts and assistance to individual members, non-members, publicly traded pawn companies, and/or pawnbroker groups grows daily. That list along with the supporting documents and links is being placed on the NPA website.
Sarah Jane Hughes