On July 20, 2022, the Connecticut Department of Banking (the “Department”) issued a Consumer and Industry Advisory on Money Transmission (the “Advisory”). The Department believes the Advisory was necessary for two reasons. First, the Department notes the “significant disruption to traditional money transmission systems” caused by the “increased use of technology to enable immediate payment mechanisms” and “the explosion of virtual currency.” … 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
Connecticut is the next in a growing list of states to pass comprehensive data privacy legislation. Last Friday, the Connecticut legislature passed, by large margins, Senate Bill 6 — which we are referring to as the Connecticut Data Privacy Act (CTDPA). The law now awaits the Governor’s signature.
The CTDPA follows the form and content of other privacy laws passed in the prior year, including the Colorado Privacy Act (CPA), Virginia Consumer Data Protection Act (VCDPA), and Utah Privacy Act (UPA). … Continue Reading
The Connecticut federal district court has ruled in Pennsylvania Higher Education Assistance Agency v. Perez that demands by the Connecticut Department of Banking (DOB) to the Pennsylvania Higher Education Assistance Agency (PHEAA) for federal student loan documents are preempted by federal law. PHEAA was represented by Ballard Spahr.
PHEAA services federal student loans made by the Department of Education (ED) under the Direct Loan Program pursuant to a contract between the ED and PHEAA. … Continue Reading
In August 2018, we reported about significant changes to Connecticut’s licensing laws for consumer financial services providers that were to take effect on October 1, 2018. In our blog post, we highlighted a new requirement (which appeared to be unprecedented), for sales finance companies to acquire and maintain information about the ethnicity, race, and sex of applicants for motor vehicle retail installment contracts. … Continue Reading
Last week, the Connecticut Fair Housing Center, Inc. filed a complaint against Liberty Bank in Connecticut federal district court alleging that the Bank engaged in discriminatory mortgage lending in violation of the federal Fair Housing Act. The complaint describes the Bank as “the eighth-largest conventional home purchase lender and eleventh-largest refinancer in Connecticut.”… Continue Reading
Significant changes to Connecticut’s licensing laws for consumer financial services providers will take effect on October 1, 2018. In addition to changes impacting mortgage-related licensees (e.g. mortgage lenders, originators and brokers), Public Act 18-173 revises or creates new licensing requirements for many providers including small loan lenders, sales finance companies, money transmitters, check cashers, debt adjustors, debt negotiators, collection agencies, student loan servicers, and mortgage servicers.… Continue Reading
D.C. License Applications. The District of Columbia Department of Insurance, Securities and Banking recently started to accept applications and transition fillings for a Student Loan Servicer License on the National Mortgage Licensing System (NMLS).
The District of Columbia’s Student Loan Act, which became effective on February 18, 2017, provides that no person or entity, unless exempt, can service a “student education loan” of a “student loan borrower” in the District, directly or indirectly, without first obtaining a license. … Continue Reading