The Conference of State Bank Supervisors (CSBS) on September 16, 2026 released an Artificial Intelligence Supervisory Framework designed to help state financial examiners identify and understand how the bank and non-bank institutions they regulate are using artificial intelligence, assess the associated risks, and determine when a more in-depth review may be appropriate.… Continue Reading
State Licensing
Chopra: New agency to focus on harmful and corrupt practices that drive up costs
By Ballard CFS Group on
The new California Business and Consumer Services Agency (BCSA), launched on July 1, 2026, will focus on improper practices that drive costs up for state residents, agency Secretary Rohit Chopra said, in a recent blog post.
“A key priority for the agency is to crack down on harmful and corrupt practices that wrongfully raise costs for families and honest businesses,” Chopra wrote.… Continue Reading
Oregon Proposes Guidance Requiring Nonbank BNPL Providers and Service Providers to Obtain State Lending Licenses
The Oregon Department of Consumer and Business Services, Division of Financial Regulation (DFR), has proposed to issue Bulletin No. DFR 2026-X, reminding nonbank “Buy Now, Pay Later” (BNPL) companies and BNPL service providers that they generally must obtain Oregon lending licenses before offering BNPL products to Oregon consumers. Unlike a few other states, Oregon has not enacted a statute that specifically applies to BNPL companies and service providers.… Continue Reading
Illinois Enacts Licensing and Supervisory Framework for Buy Now, Pay Later Providers
Posted in Buy Now Pay Later, State Licensing
On June 25, 2026, Illinois Governor J.B. Pritzker signed into law the Buy-Now-Pay-Later Loan Consumer Protection Act (the “Act”), Public Act 104-475. The legislation establishes a comprehensive licensing and supervisory framework for providers of buy now, pay later (“BNPL”) products operating in Illinois.
The Act, which becomes effective on January 1, 2028 (unless a later effective date is provided by rule), places Illinois among the first states to enact a regulatory regime specifically tailored to BNPL products, although BNPL products are covered by existing laws in a number of states.… Continue Reading
Louisiana earned wage access law goes into effect
By Daniel Wilkinson & Joseph J. Schuster on
An earned wage access (EWA) law has gone into effect in Louisiana. The legislation, passed earlier this year, became law without the signature of Gov. Jeff Landry.
The legislation’s sponsor, state Rep. Vinney St. Blanc told the Louisiana Radio Network that if you’re a health care provider or a nurse and your child breaks his arm, “I have something.… Continue Reading
New York Gov. Hochul signs legislation that includes BNPL Licensing Requirements and other Consumer Protection Provisions
By Ballard CFS Group on
Posted in State Enforcement, State Licensing
New York Gov. Kathy Hochul has signed legislation that, among other things, imposes new licensing requirements on Buy Now, Pay Later services.
In touting the FY26 budget bill that contained the consumer protection provisions, Hochul commented, “Our tax cuts, credits, and rebates won’t be much help if bad actors are able to scam or mislead New Yorkers.… Continue Reading
Ballard Spahr launches State Attorneys General Consumer Response Team to respond to state issues
By Ballard CFS Group on
State attorneys general are not waiting to see what the future holds for the CFPB. With federal oversight receding, states are stepping up enforcement activities and strengthening their consumer protection laws.
This shift—accelerated by efforts to limit the CFPB’s authority under the Trump administration—creates a complex landscape where businesses must navigate a patchwork of state-level statutes, regulations, and enforcement priorities.… Continue Reading
California’s DFPI seeks comments on additional products and services to be registered under the CCFPL
In the wake of the Office of Administrative Law’s approval of its registration and reporting requirements for providers of income-based advances, private postsecondary education financing, debt settlement services, and student debt relief services, California’s Department of Financial Protection and Innovation (“DFPI”) has issued an invitation for comment on “what other industries…the DFPI should establish registration and reporting requirements for under the [California Consumer Financial Protection Law].”… Continue Reading
PA Department Of Banking And Securities: virtual currency is “money”
On April 20, 2024, the Pennsylvania Department of Banking and Securities (“DoBS”) issued a policy statement (“Policy Statement”) to “clarify” that the Department’s interpretation of the term “money” in the Pennsylvania Money Transmitter Act (“MTA”) includes “virtual currency, such as Bitcoin.” The MTA provides in part that “[n]o person shall engage in the business of transmitting money by means of a transmittal instrument for a fee or other consideration with or on behalf of an individual without first having obtained a license from the department.’”… Continue Reading
Wisconsin and Maine enact Model Money Transmission Modernization Law
By John D. Socknat & Ballard CFS Group on
Posted in Money Transmission, State Licensing
In April 2024, Wisconsin and Maine enacted the Model Money Transmission Modernization Law (“MTML”) to implement the Conference of State Bank Supervisors’ Model Money Transmission Modernization Act. As of April 22, 2024, twenty-one states have fully or partially enacted the model act, and eight additional states having legislation pending.
On April 4, 2024, Wisconsin enacted the MTML, which becomes effective January 1, 2025. … Continue Reading