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DFI Licensed Lenders and Payday Lenders Should Be Cautious During COVID-19 Crisis

On March 18, 2020, the Wisconsin Department of Financial Institutions (“DFI”) issued emergency guidance to licensed lenders and payday lenders cautioning them from increasing customary interest rates, fees, or any costs of borrowing in response to the COVID-19 crisis.

DFI explicitly warned that increases will be monitored closely and that any increases could subject the lender to an adverse finding. In other words, any such increases in response to the COVID-19 crisis would be deemed “an essential failure of [the lenders’] character and fitness.”

DFI further warned that willfully engaging in opportunistic and exploitative conduct could result in the suspension or revocation of the lender’s license under the character and fitness requirements for businesses, officers, and directors.

Additionally, DFI encourages lenders to “reduce your rates and fees as low as operational expenses and sound lending practices allow” so that lenders can be a solution to help struggling Wisconsin families and businesses navigate these difficult times.

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About this Author

Sherry Coley Litigation Attorney Davis Kuelthau
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Sherry is a member of Davis|Kuelthau’s Litigation Team practicing in the Green Bay office. Her practice primarily focuses on complex business litigation, with an emphasis on contract disputes, business torts, financial services litigation, real estate foreclosures and work-outs, and tax assessment appeals.

Sherry is also a member of the Intellectual Property Team representing clients in district courts across the country, as well as, in the Ninth and Federal Circuit Court of Appeals. She has litigated patent, trademark, copyright, unfair competition and trade secret cases in a wide...

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Tiffany Woelfel Davis Kuelthau Litigation Attorney
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Tiffany Woelfel is a member of the firm’s Litigation Practice in Davis|Kuelthau’s Green Bay office.

Prior to joining the firm, Tiffany was a judicial law clerk for the Honorable William C. Griesbach, Chief Judge of the United States District Court for the Eastern District of Wisconsin, and for the Honorable Joe B. McDade, Senior Judge in the United States District Court for the Central District of Illinois. While in law school, she was also a judicial intern for the Honorable William M. Conley, Judge for the Western District of Wisconsin. She gained experience in the federal law and civil procedure, as well as Wisconsin and Illinois state law.

While in law school, Tiffany was on the executive board of the Wisconsin Moot Court board and member of the Wisconsin Law Review. She also gave back to her community and completed over 150 pro bono hours while in school. In 2016, she was named the Dane County Bar Association Pro Bono Publico Law Student of the Year.

Before law school, she double majored in International Business and Non-profit Management at the University of Minnesota. She also spent two years teaching sixth grade math in Mississippi as part of Teach for America.

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