On May 19, 2016, the Vermont Attorney General announced that it had executed an Assurance of Discontinuance with a payment processor arising out of the Attorney General’s allegation that the payment processor violated a Vermont state statute prohibiting unfair and deceptive practices when the processor processed payments for dozens of payday lenders who did not have the appropriate state lending licenses.  All loans made in Vermont must comply with the interest rate limits between 12-24% per annum, depending on the type of loan.  The payment processor agreed to pay a $25,000 fine, make restitution to affected Vermont residents (about $153,000), and notify the Vermont Attorney General’s office if it decides to conduct business in the state again.  According to the Assurance of Discontinuance, it is an unfair and deceptive act in Vermont for any lender to solicit or make loans in Vermont unless the lender is in compliance with all statutory requirements under Vermont’s lending laws.  It is also an unfair and deceptive act in commerce for a processor to process checks or debits, or to transfer any electronic funds in connection with a loan in which the lender is not in compliance with all legal requirements.  The payment processor at issue, according to the Assurance of Discontinuance, processed electronic transfers from various financial institutions employing routing numbers associated with Vermont, on behalf of lenders “in connection with high-interest, small-dollar consumer loans made via the internet.”  The Attorney General’s office determined that none of the lenders were licensed to make loans in Vermont.