A&B ABstract: As we have previously discussed, effective November 27, 2019, Senate Bill 1149 (2019 N.J. Laws 200) (the “Act”), creates New Jersey’s “Student Loan Bill of Rights” and prohibits any person from “act[ing] as a student loan servicer, directly or indirectly, without first obtaining a license” from the Department of Banking and Insurance (“DOBI”). […]
Licensing
Louisiana Enacts Virtual Currency Company Law
A&B ABstract: On June 13, Louisiana enacted a comprehensive new law imposing a licensing obligation on entities that engage in virtual currency business activity. Effective August 1, 2020, House Bill 701 (the “Law”) will require the licensure of entities that engage in virtual currency business activity in Louisiana with Louisiana residents. The Law provides that an […]
Virginia Enacts Student Loan Servicing Law
A&B ABstract: On April 22, Virginia enacted a comprehensive new law imposing a licensing obligation on private student loan servicers and substantive restrictions on both private and federal student loan servicers. Effective July 1, 2021, House Bill 10 and Senate Bill 77 (the “Law”) will require the licensing of and regulate student loan servicers. […]
Federal and State Guidance Regarding the COVID-19 Pandemic
A&B Abstract: The Alston & Bird Consumer Finance team recognizes that this is a period of great uncertainty both for the nation and our clients. We have received numerous questions and concerns regarding what federal and state regulators are doing in light of the COVID-19 pandemic and how their response may affect day-to-day business. We […]
New York Financial Regulator Requires COVID-19 Risk Assessment, Operational Planning
Last week the New York Department of Financial Services (the “Department”) issued letters to all its licensed financial institutions. Based on these letters (available here and here), all Department licensees must assess and plan for the financial risk of COVID-19 and, separately, develop operational plans for managing their response to the virus. The Department requires written responses “as […]