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Wisconsin Senate Proposes New Bill to Revise Money Transmission, Consumer Lenders, Collection Agency, and Other Financial Services...

In November 2023, S.B. 668 was introduced in the Wisconsin Senate. S.B. 668 would make sweeping changes to the state laws governing financial service providers. The bill creates a pathway for the Wisconsin Department of...more

FinCEN Proposes to Require Recordkeeping and Reporting for CVC Mixing Transactions

On October 23, the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“NPRM”) entitled Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of...more

California DFPI Finalizes Regulations Governing Student Loan Servicers

On October 13, 2023, the California Department of Financial Innovation (DFPI) published final regulations implementing the Student Loan Servicing Act (“SLSA”) and the Student Loans: Borrower Rights Law. The final regulations...more

Amendments to Ohio’s Administrative Rules Relating to Residential Mortgage Lending

The Ohio Department of Commerce, Division of Financial Institutions is amending the rules that implement the state’s Residential Mortgage Lending Act. The Division is seeking preliminary feedback on the administrative rules,...more

Missouri joins state efforts to regulate earned wage access providers

On August 28, 2023 (the “Effective Date”), SB 103, signed into law by Missouri’s governor, will become the nation’s second statutory framework for earned wage access (EWA) providers.  The Missouri law closely resembles...more

Kentucky student loan servicer license application available on NMLS

Last year, Kentucky enacted the Student Education Loan Servicing, Licensing, and Protection Act of 2022 (the “Act”), which requires student loan services to be licensed in Kentucky.  The Act took effect on July 13, 2023 (the...more

NYDFS releases Industry Guidance Letter on Assessment of the Character and Fitness of Directors, Senior Officers, and Managers

NYDFS recently issued Proposed Guidance “to New York State-regulated banking organizations and regulated non-depository financial institutions to notify them of the Department’s expectation that they update their framework...more

Washington Department of Financial Institutions Issues Regulations On Work From Home Effective December 31, 2022

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...more

Washington Department of Financial Institutions issues regulations on work from home effective 12/31

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...more

Utah and Virginia enact registration and disclosure requirements for providers of merchant cash advances

Utah and Virginia recently became the first two states to require the registration of providers of merchant cash advances.  The new laws also include disclosure requirements.  (Although laws requiring disclosures for merchant...more

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