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Trigger Leads – Don’t Forget about the States

As Rich Andreano blogged on April 15, 2025, legislation to prohibit or restrict so-called “trigger leads” in the home-buying process has been reintroduced in the House and Senate. The legislation has broad industry and...more

CFPB revokes EWA advisory opinion

The CFPB rescinded an advisory opinion that had described how one particular type of “earned wage” product did not involve the offering or extension of “credit” as that term is defined in the Truth in Lending Act and...more

FinCEN Renews Real Estate GTOs: Expanded Geographic Coverage and Reduced Monetary Thresholds

The Financial Crimes Enforcement Network (“FINCEN”) announced on November 15 that it has renewed and revised its Geographic Targeting Orders (“GTOs”) that require U.S. title insurance companies to identify the natural persons...more

NMLS Renewal Period Now Open

A reminder that the NMLS license renewal period opened on November 1, and that there is an Annual Renewal Information section on the NMLS Resource Center website with detailed information regarding deadlines, requirements,...more

Vermont exempts bank partners from loan solicitation license for commercial loans

We have been following closely efforts by state regulators, state legislatures and the courts to restrict, or in some cases prohibit, bank model lending programs, so the recent guidance from the Vermont Department of...more

Illinois Revises Advertisement "Tag Line" Requirement

Effective immediately, Illinois Residential Mortgage licensees will no longer be required to include the phrase "Illinois Residential Mortgage Licensee" in advertisements...more

North Carolina to Accept Electronic Surety Bonds

The North Carolina Commissioner of Banks Office has begun receiving new and converted Electronic Surety Bonds (ESB) through NMLS for its mortgage broker, mortgage lender, and mortgage servicer licenses....more

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