State Licensing

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After looking at CSBS’s role in the system of state financial supervision, we discuss CSBS initiatives to coordinate state licensing and supervision of multi-state non-bank companies, such as by implementing a “one company-one exam” approach and multi-state licensing program, its work on a model law for money services businesses, why CSBS opposes an OCC fintech…

The Conference of State Bank Supervisors (CSBS) recently announced plans to establish a program under which money transmitters licensed in multiple states will undergo a single comprehensive exam that seeks to satisfy all state examination requirements, beginning in 2021. Money transmitters, payments firms and cryptocurrency companies licensed in 40 or more states would be covered…

As part of California’s recent triad of consumer financial services legislation, including AB-1864, which creates the Department of Financial Protection and Innovation and the California Financial Protection Law, and AB-376, which includes a new Student Loan Borrower Bill of Rights.  California is also on the cusp of enacting a law requiring licensure of…

We previously blogged about Virginia’s enactment last month of a law requiring student loan servicers to be licensed by the Virginia State Corporation Commission (“Commission”). As promised, we are providing a more detailed summary of HB 10/SB 77, which is undoubtedly one of the most sweeping laws we’ve seem to date targeted at regulating student…

One Wednesday, Virginia enacted a law that requires student loan servicers to be licensed.  While Virginia opened its “Office of the Qualified Education Loan Ombudsman” in 2019, efforts to require licensure of student loan servicers had previously failed.

Identical bills HB 10/SB 77 had been sent to Governor Northam’s desk on March 12, but were…

On December 30, 2019, the California Department of Business Oversight (DBO) announced two actions regarding companies offering unregulated, point-of-sale financing to California residents.  In the first action,  the DBO denied the application of Sezzle Inc. for a lender’s license under the California Financing Law (CFL).  According to the DBO in its Statement of Issues,…

The New York Department of Financial Services (NYDFS) has issued proposed regulations to implement the legislation enacted in April 2019 that requires servicers of student loans to be licensed, imposes servicing standards, and prohibits certain practices.  On July 31, the NYDFS published a notice of proposed rulemaking in the State Register, triggering a 60-day…

On July 30, 2019, Acting New Jersey Governor Sheila Oliver signed into law SB 1149, which requires student loan servicers to be licensed, creates an Office of the Student Loan Ombudsman within the NJ Department of Banking and Insurance, imposes various requirements, and prohibits certain conduct.  The law takes effect 120 days after enactment.…

As recently reported, the Washington, D.C. Department of Insurance, Securities, and Banking (DISB) published a Bulletin in late April reminding those who service student education loans in the District of Columbia of their obligation to file an annual report. The DISB has now released the required forms for both the 2018 and 2019 filings.…