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On October 31, the Ohio Division of Financial Institutions (DFI) issued updated Bank Partnership Guidance under the state’s Small Loan Act, reversing its earlier position from December 2024 and January 2025. The DFI had previously advised that any nonbank entity arranging consumer loans of $5,000 or less in exchange for compensation, including loans originated by federally insured banks, would be required to obtain a state license. The latest guidance withdraws that interpretation and pauses licensing and enforcement for the near term.Continue Reading Ohio DFI Withdraws Prior Interpretation, Suspends Licensing for Bank Loan Arrangers Under Small Loan Act

On September 26, 2025, financial regulators in Hawaii, Idaho, Oregon, and Texas entered into a multistate Settlement Agreement and Consent Order with a mortgage company to resolve allegations of unlicensed activity, inadequate supervision, and examination noncompliance under each state’s mortgage licensing laws. The agreement followed a coordinated multistate examination conducted in October 2023.Continue Reading Four States Settle with Mortgage Company for Alleged Unlicensed Activity

On September 8, the D.C. Attorney General filed a lawsuit in D.C. Superior Court against a crypto ATM operator alleging violations of the Consumer Protection Procedures Act and the Abuse, Neglect, and Financial Exploitation of Vulnerable Adults and the Elderly Act. The suit also alleges unlicensed money transmission activity in the District.Continue Reading D.C. Attorney General Sues Crypto ATM Operator for Alleged CPPA and Elder-Exploitation Violations

On August 8, the U.S. District Court for the District of Maryland issued an opinion partially granting an earned wage access (EWA) provider’s motion to dismiss that challenged whether the company operated as an unlicensed lender in violation of the Maryland Consumer Loan Law (MCLL), charged unlawful fees, and failed to comply with disclosure obligations under the Truth in Lending Act (TILA). Plaintiffs also alleged the company violated the Maryland Consumer Protection Act’s (MCPA) prohibition on unfair or deceptive trade practices with respect to extensions of credit.Continue Reading District Court Allows Federal TILA and Maryland Consumer Loan Law Claims to Move Forward Against Earned Wage Access Provider

On August 15, the Illinois Department of Financial and Professional Regulation proposed regulations to implement recent amendments to the Residential Mortgage License Act of 1987 (RMLA) covering “shared appreciation agreements.” The proposed revisions treat these agreements as residential mortgage loans subject to RMLA licensing and compliance requirements.Continue Reading Illinois Proposes Regulations for Shared Appreciation Agreements Under the Residential Mortgage License Act

On August 7, Illinois enacted Senate Bill 2457, amending the Collection Agency Act and removing its January 1, 2026 repeal date under the Regulatory Sunset Act. The law retains the licensing framework for collection agencies and debt buyers while revising definitions, exemptions, and enforcement provisions under the Act.Continue Reading Illinois Expands Collection Agency Act with New Licensing and Enforcement Provisions

On May 28, Nevada Governor Joe Lombardo approved SB 437, creating a new framework for internet-based consumer lenders that lend to Nevada residents. The law defines an “Internet consumer lender” as any entity that exclusively offers or facilitates consumer loans online and becomes effective on October 1, 2025.Continue Reading Nevada Enacts Law Allowing Remote Licensing for Internet Consumer Lenders

On May 28, Maryland Governor Wes Moore signed House Bill 1294 into law, establishing a comprehensive regulatory framework for Earned Wage Access (EWA) providers operating in the state. Effective October 1, the new law provides for licensing of both employer-integrated and consumer-directed EWA providers under the Maryland Consumer Loan Law, while also introducing a host of new consumer protection requirements.Continue Reading Maryland Enacts Earned Wage Access Law

On May 6, Indiana Governor Mike Braun signed House Enrolled Act No. 1125 into law, making Indiana the latest state to enact a statutory framework for regulating earned wage access (EWA) products.  The Indiana Earned Wage Access Act, which takes effect January 1, 2026, requires most EWA providers to obtain a license from the Indiana Department of Financial Institutions and comply with operational, disclosure, and consumer protection requirements.  Continue Reading Indiana Enacts Earned Wage Access Law 

On January 10, 2025, the Maryland Office of Financial Regulation (OFR) issued guidance significantly expanding licensing requirements for assignees of residential mortgage loans in Maryland. The guidance stems from an April 2024 court ruling and raises important considerations for entities involved in the secondary mortgage market.Continue Reading Maryland Expands Licensing Requirements for Mortgage Loan Assignees