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Virginia Approves Bill Allowing Banks to Offer Cryptocurrency Custody Services

On March 3, Virginia passed a new bill (HB 263) permitting banks in the Commonwealth to provide its customers with crypto custody services “so long as the bank has adequate protocols in place to effectively manage risks and...more

DFPI Approves EWA Provider

On February 11, the California DFPI issued an opinion letter in response to an EWA provider’s request for a specific ruling from the DFPI about whether the company’s EWA solution is subject to licensure under the California...more

California and Georgia Reach Settlement with Rent-to-Own Companies

In two unrelated settlements, the California DFPI and Georgia attorney general each recently settled with rent-to-own companies. In the California settlement that was announced on January 10, the DFPI settled with a Los...more

OCC Prevails in Challenge to “Valid When Made” Rule

On February 8, the U.S. District Court for the Northern District of California ruled against three states – California, Illinois, and New York – challenging the OCC’s rule on the “valid when made” doctrine. In 2020, the OCC...more

New York Makes Remote Online Notarizations Permanent

On December 22, New York Governor, Kathy Hochul, signed Senate Bill 1780C (S1780C), which allows the state’s notaries to conduct remote online notarizations (RON). The law is to be effective on June 20, 2022. Among other...more

DFPI Reports Increase in Consumer Loans Under $2,500, Decrease in Consumer Loans Between $2,500 and $10,000

On November 16, the California DFPI released Version 2.0 of its Annual Report of Finance Lenders, Brokers and PACE Administrators Licensed under the California Financing Law (CFL). The Annual Report examined unaudited data...more

New York Enacts Consumer Credit Fairness Act, Impacting Debt Collection Actions

On November 8, New York Governor Kathy Hochul signed into law the Consumer Credit Fairness Act (Act) (S.153/A.2382). The Act contains a series of amendments to New York’s Civil Practice Law and Rules (CPLR) that...more

NYDFS Issues Proposed Rules to Implement New Commercial Financing Disclosure Law

On October 20, the New York Department of Financial Services (NYDFS) issued proposed rules under New York’s Commercial Financing Disclosure Law (CFDL) (See S5470-B, as amended by S898). Under the CFDL, commercial financing...more

Hawaii Amends Small Dollar Lending Law

Hawaii recently enacted HB 1192, which amends the state’s small dollar lending law by setting forth a new licensing requirement for “installment lenders” and specifies various consumer protection requirements.  The...more

Money Transmission Licenses Required for Virtual Currency Activities in Arkansas and Florida

Recently Florida and Arkansas made it a requirement for those engaging in virtual currency activities to obtain money transmission licenses in their respective jurisdictions. - In August, the Florida Office of Financial...more

Wyoming and Maine Issue New Licensing Requirements Potentially Impacting Passive Loan Investors

Wyoming and Maine recently amended their laws related to licensure requirements for consumer lending: - In July, Wyoming adopted House Bill 0008 (HB 0008), which amends provisions of the Wyoming Uniform Consumer Credit...more

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