On January 17, 2023, House Bill No 2389 was offered to re-enact sections 6.2-1600 (Definitions) and 6.2-1607 (Licenses; places of business; changes) of the Code of Virginia with proposed amendments that would permit employees...more
2/27/2023
/ Employer Liability Issues ,
Financial Services Industry ,
Labor Reform ,
Mortgage Brokers ,
Mortgage Lenders ,
Proposed Legislation ,
Regulatory Agenda ,
Remote Working ,
State Labor Laws ,
Telecommuting ,
Virginia
After reviewing the licensing/chartering/approval structures that DFS uses for entities seeking to engage in virtual currency activities, we discuss the role of guidance in DFS’s regulation and oversight of virtual currency,...more
On January 23, 2023, the New York Department of Financial Services released guidance with the stated goal of helping to protect customers of virtual currency businesses in the event of an insolvency or similar proceeding by...more
On September 9, 2022, the California Department of Financial Protection and Innovation (DFPI) proposed to amend its student loan servicing regulations, which we previously covered here. After reviewing public comments, on...more
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
On December 15, 2022, the New York Department of Financial Services (“NYDFS”) published an Industry Letter detailing the Department’s guidance regarding banking organizations that wish to engage in virtual currency-related...more
In Mortgagee Letter 2022-22 dated December 15, 2022, the FHA announced updates to its Single Family Housing Policy Handbook (HUD Handbook 4000.1) that modifies its policies governing conflicts of interest and dual employment....more
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
The New York state legislature is currently considering a pair of companion bills which would impose detailed notice and records requirements upon student loan servicers. New York Senate bill S5136B, which was passed by the...more
New York Assembly Bill A3081, signed by Governor Kathy Hochul on November 21, effectively preempts any local law that would require mortgage lenders to register mortgages in default at any point prior to the filing of a...more
On December 12, 2022, the CFPB released a proposed rule that would require certain “covered nonbanks” to register with and submit information to the CFPB when they become subject to certain orders from local, state, or...more
On December 22, 2021, New York State Senate Bill 2767A was signed into law. The Bill establishes the Private Student Loan Refinancing Task Force (the “Task Force”), which was charged with “study[ing] and analyz[ing] ways...more
On November 3, 2022, Pennsylvania enacted Act No. 142, effective immediately. The Act modifies the existing statutory provisions permitting remote work by revising the definition of “remote location” set forth in section in...more
We previously reported that the Oregon Division of Financial Regulation (the Division) amended its administrative rules pertaining to branch licensure to authorize remote work for licensed loan originators and employees. The...more
Following up on our previous articles reporting on recent state developments regarding work from home...more
On August 31, 2022, the California Senate voted to approve House Assembly Bill 156, and sent the bill to Governor Newsom for consideration and potential signature. If it becomes law, the bill would amend the existing...more
On September 9, 2022, the California Department of Financial Protection & Innovation (the “DFPI”) released a Notice of Proposed Rulemaking Action that proposes to adopt regulations implementing the Student Loan Servicing Act...more
On August 8, 2022, the District of Columbia Department of Insurance, Securities and Banking (the Department”) issued a Bulletin on money transmission (the “Bulletin”). The Department issued the Bulletin to ensure that...more
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. ...more
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. ...more
Private education lenders doing business in Illinois now have access to official informational guides and templates for meeting the November 1, 2022, reporting requirements under the state’s new Know Before You Owe Private...more
As discussed in an earlier blog post, the California Department of Financial Protection and Innovation (“DFPI”) issued an Invitation for Comments on the Proposed Second Rulemaking under the Debt Collection Licensing Act...more
On June 27, the Oregon Department of Consumer and Business Services’ (“Department”) Division of Financial Regulation (“Division”) finalized new regulations implementing Senate Bill 485, which requires companies to obtain a...more
There continues to be a trend towards extending, and in some cases, codifying through regulation or statute, emergency COVID-19 guidance enabling work from home. Most recently...more
On June 18, 2022, Louisiana’s Governor signed into law two new bills that impose new requirements for student loans. Both bills are effective on August 1, 2022....more