CARES Act Economic Impact Payments for Individuals and Payment Protection Program Loans for Small Businesses: Are They Subject to Garnishment or Setoff?

We look at the impact of federal and state law including relevant CARES Act provisions, state garnishment directives, and federal preemption, identify issues banks should consider in handling garnishments or exercising setoff rights, and offer suggestions for mitigation measures banks can take as they decide how to address the challenges in this area.

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