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Jan 24, 2025 | 
mondaq.com | Krista Cooley |Francis L. Doorley |Steven A. Kaplan |Kelly Kramer
On January 10, 2025, the Maryland Office of Financial Regulation(OFR) issued formalguidance asserting that assignees of residential mortgageloans—including certain "passive trusts" thatacquire or obtain assignments of residential mortgage loans inMaryland—must become licensed in Maryland prior to April 10,2025, unless the assignee is expressly exempt under Maryland law.
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Jan 22, 2025 | 
mondaq.com | Amanda Baker |Christa L. Bieker |Krista Cooley |Francis L. Doorley
As we enter 2025, the primary and secondary markets for consumerand small business financial assets remain robust. Like last year,many new securitization issuances are planned for the firstquarter, and financial services companies continue to expand theirexisting offerings and innovate new products. Nonetheless, navigating the rapidly evolving regulatoryenvironment remains a top priority for those in the consumer andsmall-business financing space.
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Jan 16, 2025 | 
mondaq.com | Francis L. Doorley |Steven A. Kaplan |Kristie D. Kully |Joy N Tsai
On December 17, 2024, the Consumer Financial Protection Bureau(CFPB or Bureau) issued its final rule (Final Rule) applying certainresidential mortgage requirements to Property Assessed Clean Energy(PACE) financing. The CFPB issued the Final Rule in response to theEconomic Growth, Regulatory Relief, and Consumer Protection Act(EGRRCPA), which required the CFPB to issue regulations applyingthe Truth in Lending Act's (TILA) ability to repay and civilliability provisions to PACE financing.
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Nov 1, 2024 | 
mondaq.com | Krista Cooley |Francis L. Doorley
Licensing Link is a periodic publication that will keep
you informed on hot topics and new developments in state licensing
laws, and provide practice tips and primers on important issues
related to state licensing across the spectrum of asset classes and
financial services activities. We hope you'll join us for
future editions.
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Nov 1, 2024 | 
mondaq.com | Krista Cooley |Francis L. Doorley
On October 22, 2024, the California Department of Financial
Protection (DFPI) issued final regulations which, when effective,
will classify most EWA programs in the market as consumer loans,
and which subject EWA providers to registration and regulation
under California's consumer-credit laws.
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Nov 1, 2024 | 
mondaq.com | Krista Cooley |Francis L. Doorley |Jeffrey Taft |Daniel Pearson
Legislation signed into law by California Governor Gavin Newsom
on September 24, 2024 will subject commercial debt collectors to
new compliance requirements starting in 2025. California Senate Bill 1286 extends the reach
of the state's Rosenthal Fair Debt Collection Practices Act
(the "Rosenthal Act"), California's primary law
regulating debt collection practices, to also cover certain small
business or commercial debts in addition to consumer debts.
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Sep 16, 2024 | 
mondaq.com | Krista Cooley |Francis L. Doorley
For more than 20 years, our Financial Services Regulatory and
Enforcement practice's licensing team has helped clients
engaged in lending and other consumer credit activities navigate
every aspect of state licensing.
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Jul 30, 2024 | 
jdsupra.com | Krista Cooley |Francis L. Doorley
Washington recently enacted significant changes to its Consumer Loan Act that may bring certain nonbank loan marketers and program managers within its scope. The Consumer Loan Act requires a license to make consumer loans of any dollar amount that bear a finance charge, including both mortgage and non-mortgage loans.
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Jul 30, 2024 | 
jdsupra.com | Krista Cooley |Francis L. Doorley
In addition to the states that, similar to Washington, have adopted “true lender” provisions, several states have recently enacted changes to their consumer loan licensing laws that expand the scope of the licensing obligation to sweep additional parties participating in the origination, servicing, and sale of non-mortgage consumer loans under the scope of the state consumer loan licensing law. Wisconsin is set to follow this trend now that Governor Tony Evers has signed Senate Bill 668 into law.
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Jul 26, 2024 | 
mondaq.com | Krista Cooley |Francis L. Doorley
Washington recently enacted significant changes to its Consumer
Loan Act that may bring certain nonbank loan marketers and program
managers within its scope. The Consumer Loan Act requires a license
to make consumer loans of any dollar amount that bear a finance
charge, including both mortgage and non-mortgage loans.
