A&B ABstract Amid growing concerns over the federal government’s “hands off” approach to regulating the student loan business, New York Governor Andrew Cuomo released 3 NYCRR 409, a proposed regulation aimed at providing significant consumer protections for New York student loan borrowers, to the public for comment. The deadline for comment on the regulation is […]
Licensing
Nevada Adopts Regulations for Licensure by Endorsement
A&B Abstract: Nevada recently adopted new regulations allow a natural person to obtain a license by endorsement to engage in business as a mortgage broker or mortgage agent, mortgage loan servicer, or escrow agent or agency, so long as such person holds a corresponding valid and unrestricted license to engage in such business in another […]
New Jersey Joins Other States Regulating Student Loan Servicers
A&B Abstract New Jersey recently enacted its own version of a Student Loan Bill of Rights, which requires the licensing of any person acting “directly or indirectly” as a student loan servicer. In light of the growing number of states enacting similar language to regulate the student loan industry, what might this mean for the […]
Rhode Island Requires Licensure for Virtual Currency Business Activity
A&B Abstract: Effective January 1, 2020, Rhode Island will regulate virtual currency under its money transmission laws. Background Forty-nine states and the District of Columbia regulate money transmission. Almost all of those jurisdictions have different definitions and exemptions that determine whether their laws apply to certain businesses or activities. The result is a complex, patchwork […]
Maryland Clarifies New Net Worth Requirements for Mortgage Servicers
A&B Abstract: Effective October 1, 2019, the Maryland Commissioner of Financial Regulation will impose new net worth requirements on licensees. Importantly, Maryland servicing licensees without GSE approvals may not use a line of credit to satisfy the net worth requirements. However, mortgage servicers may include mortgage servicing rights in the calculation of tangible net worth. […]