Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
On August 27, the Wisconsin Department of Financial Institutions (DFI) announced it will start accepting applications for a new money transmitter license through NMLS on October 1. The new license will replace the current...more
As previously reported, in June 2024 the CFPB issued a final rule creating a Nonbank Enforcement Order Registry. The rule is effective on September 16, 2024, with registrations available beginning on October 16, 2024 pursuant...more
Increased regulation of commercial financing shows no signs of stopping. California SB 1482, which would require commercial financing providers and brokers to register with the California Department of Financial Protection...more
On June 3, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its final rule requiring covered nonbanks to register enforcement orders, and it is a doozy. Not only will covered nonbanks be required to register...more
In November 2023, S.B. 668 was introduced in the Wisconsin Senate. S.B. 668 would make sweeping changes to the state laws governing financial service providers. The bill creates a pathway for the Wisconsin Department of...more
Last year, Kentucky enacted the Student Education Loan Servicing, Licensing, and Protection Act of 2022 (the “Act”), which requires student loan services to be licensed in Kentucky. The Act took effect on July 13, 2023 (the...more
On June 13, Nevada’s governor signed into law Senate Bill 290 creating the nation’s first statutory framework for earned wage access (EWA) providers operating in the state. The law appoints the state’s Commissioner of...more
On May 8, the Maryland governor signed HB 686 to eliminate a requirement that collection agencies and certain non-depository financial institutions must maintain separate licenses for branch locations...more
April 1, 2023 marks the deadline to submit an application for the Louisiana Virtual Currency Business Activity License or Virtual Currency Limited Activity Registration in order to receive timely approval from the Louisiana...more
On August 19, the California Department of Financial Protection and Innovation (DFPI) announced the adoption of final rules transitioning the application form and certain other submissions relating to the “catchall”...more
With that in mind, financial services institutions regulated by the New York State Department of Financial Services (DFS) received a series of four industry guidance letters, issued on March 10, 2020, addressed to chief...more
The New Jersey Department of Banking and Insurance recently issued a bulletin to provide guidance relating to the licensing and registration of mortgage servicers under the New Jersey Mortgage Servicers Licensing Act. The...more
This survey summarizes several recent developments affecting bank deposits and payment systems. The U.S. department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued new guidance concerning the customer...more
If a company is keeping its Nationwide Multistate Licensing System (NMLS) record current, the renewal season should be a relatively painless exercise in fee collection. However, in addition to the normal renewal housekeeping...more
In a Request for Information (RFI) posted on the Federal Business Opportunity website last month, the Consumer Financial Protection Bureau (CFPB) solicited information from vendors so it can "better understand current,...more
NMLS MCR Enhancements - Changes have been made to the NMLS Mortgage Call Report (MCR) which have been reflected as of April 1, 2016. The changes will affect the Residential Mortgage Loan Activity (RMLA) and the...more
The Nationwide Mortgage Licensing System (NMLS) is now accepting new applications and transition filings for new industry licenses for the Connecticut Department of Banking (Department). The Department is requiring companies...more
Texas has amended its provisions relating to exemptions from the applicability of the Texas SAFE Act for certain nonprofit organizations and their residential mortgage loan originators (MLOs). Under the amendment, a nonprofit...more
Rhode Island has repealed certain banking regulations and replaced them with new regulations in order to promote uniformity. Banking Regulations 98-14 “Licensees”, 98-14.1 “Lenders and Loan Brokers”, and 98-14.4 “Check...more