The Washington Department of Financial Institutions has adopted regulations effective December 31, 2022 to implement amendments to the Consumer Loan Act permitting licensed companies to allow licensed mortgage loan originators to work from their residence without licensing the residence as a branch.

Among various amendments and clarifications to the regulations is new WAC § 208-620-660, which provides:

What is required for a Washington licensed loan originator to work from their residence without licensing the residence as a branch?Continue Reading

The Connecticut Department of Banking (“Department”) has issued a temporary cease and desist order (“Order”) that directs SoLo Funds, Inc., (“SoLo”) a fintech company that uses peer-to-peer technology to assist consumers in obtaining small dollar loans from third-party lenders, to immediately stop engaging in such activity because it is not licensed as a small loan company in Connecticut. … Continue Reading

Pursuant to the authority set forth in Section 205 of Senate Bill 1202, Connecticut’s Banking Commissioner signed an order that permits individuals engaged in certain licensable activity on behalf of certain consumer credit licensees to work from remote office locations not licensed as branch office locations.  The order, available here, extends the previous no-action position of the Commissioner and is effective July 1, 2021.… Continue Reading

The Conference of State Bank Supervisors (CSBS) announced last week that it has agreed to implement 14 recommendations made by its Fintech Industry Advisory Panel (Advisory Panel).

The Advisory Panel was formed in 2017 to identify actionable steps for improving state licensing, regulation, and non-depository supervision and for supporting innovation in financial services. … Continue Reading

Noting, among other things, “retrenchment” on the federal level, the Maryland Financial Consumer Protection Act of 2018 (HB 1634) was signed into law on May 15, 2018.

The Act’s provisions take effect October 1, 2018 and include the following:

  • Maryland Consumer Protection Act (MCPA):  Adds “abusive” practices to the existing proscription against “unfair and deceptive trade practices” and adds violations of the federal Military Lending Act and the federal Servicemembers Civil Relief Act to the list of statutes that are considered to be per se violations of the UDAAP proscription. 
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The Conference of State Bank Supervisors (CSBS) announced yesterday that seven states have agreed to a multi-state compact that, according to the CSBS, “standardizes key elements of the licensing process for money services businesses (MSB).”

The seven states consist of Georgia, Illinois, Kansas, Massachusetts, Tennessee, Texas and Washington.  The CSBS expects other states to join the compact. … Continue Reading