The Texas House and Senate introduced House Bill 700 and Senate Bill 2677 to regulate commercial sales-based financing transactions. The proposed legislation would impose standardized disclosure requirements, require broker registration, and subject these transactions to the state’s usury laws. Continue Reading Texas Legislature Proposes Disclosure Rules for Commercial Financing 

On April 16, the Colorado General Assembly enacted House Bill 25-1201, replacing the state’s prior money transmitter law with the Money Transmission Modernization Act (the “Act”). Modeled on the multistate framework developed by the Conference of State Bank Supervisors (CSBS), the Act aims to align Colorado’s licensing and oversight regime with standards adopted in other states, while updating key regulatory definitions, exemptions, prudential requirements, and enforcement tools. Continue Reading Colorado Overhauls Money Transmission Law to Align with Multistate Licensing Standards 

In January 2025, the Maryland Office of Financial Regulation (the “OFR”) issued a guidance stating that assignees of residential mortgage loans, including certain passive trusts, were required to hold a Maryland mortgage lender license and, in certain circumstances, an installment loan license (previously discussed here). In response to this, the Maryland House and Senate passed separate but identical bills known as the Maryland Secondary Market Stability Act of 2025 (the “Act”). The Act was signed into law by Maryland Governor Wes Moore on April 22, and became effective immediately. Continue Reading Maryland Enacts Law Exempting Passive Trusts from Mortgage and Installment Loan Licensing Requirements

On April 11, North Dakota enacted HB 1127, overhauling its regulatory framework for financial institutions and nonbank financial service providers. The law amends multiple chapters of the North Dakota Century Code and creates a new data security mandate for financial corporations—a category that includes non-depository entities regulated by the Department of Financial Institutions (DFI). It also expands the licensing requirement for brokers to include “alternative financing products,” potentially impacting a broad array of fintech providers.Continue Reading North Dakota Expands Data Security Requirements and Issues New Licensing Requirements for Brokers

On April 17, Ohio Attorney General Dave Yost announced that the state has filed a lawsuit against a wholesale mortgage lender, alleging that the company engaged in a statewide scheme to mislead borrowers and inflate mortgage costs through deceptive broker steering practices. The AG’s office is seeking a jury trial on all claims.Continue Reading Ohio AG Sues Mortgage Lender for Illegal Broker Steering Scheme

On April 14, New York Attorney General Letitia James announced two separate lawsuits against earned wage access providers—one against a company that issues advances directly to consumers, and another targeting a provider that operates through employer partnerships. Both actions allege that the companies engaged in illegal payday lending schemes, charging fees and tips that resulted in annual percentage rates (APRs) far in excess of New York’s civil and criminal usury caps.Continue Reading New York AG Sues Earned Wage Access Companies for Allegedly Unlawful Lending Practices

On March 20, the New York Department of Financial Services (NYDFS) entered into a consent order with a money transmitter, joining a group of state financial regulators acting through a multi-state task force coordinated by the Conference of State Bank Supervisors (CSBS) and the Money Transmitter Regulators Association (MTRA). The regulators alleged that the company violated state money transmission laws by failing to satisfy outstanding transmission liabilities, maintain adequate net worth and permissible investments, and continue licensed operations in a financially sound manner.Continue Reading NYDFS Joins Multistate Action Against Money Transmitter for Financial and Licensing Violations

Utah and Arkansas have enacted new legislation governing earned wage access (EWA) services, establishing state-level registration obligations and consumer protection standards. Both laws clarify that EWA services are not loans under state law if certain conditions are met, including limitations on fees, debt collection, and credit reporting.Continue Reading Utah and Arkansas Enact Earned Wage Access Regulations

On March 24, Kentucky enacted House Bill 701, establishing a statutory framework to support blockchain-based activity and clarifying the treatment of digital assets under state law. The legislation defines key terms, permits the use of digital assets in commerce, and amends sections of Kentucky’s securities and financial services laws to improve regulatory clarity around crypto-based activities.Continue Reading Kentucky Enacts New Law Establishing Legal Framework for Blockchain and Digital Assets

On March 25, Virginia Governor Glenn Youngkin vetoed two bills that sought to impose new restrictions on “high-risk” artificial intelligence (AI) systems and fintech lending partnerships. The vetoes reflect the Governor’s continued emphasis on fostering innovation and economic growth over introducing new regulatory burdens.Continue Reading Virginia Governor Vetoes Rate Cap and AI Regulation Bills

On January 17, the Pennsylvania Attorney General filed a civil enforcement action in the U.S. District Court for the Eastern District of Pennsylvania against a group of mortgage brokers and their manager, alleging that they operated an unlawful referral scheme in violation of the Real Estate Settlement Procedures Act (RESPA), the Consumer Financial Protection Act (CFPA), and Pennsylvania’s Unfair Trade Practices and Consumer Protection Law.Continue Reading Pennsylvania AG Alleges Mortgage Brokers Engaged in Illegal Referral Scheme