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Paul Boller helps clients navigate a variety of federal and state statutory and regulatory requirements in consumer financial services.

On November 25, the Consumer Financial Protection Bureau announced settlements with a military travel lender, its principal, and the servicer of its loans. The now defunct Edmiston Marketing, LLC, operating under the name of Easy Military Travel, provided financing to military servicemembers and their families for the purchasing of airline tickets. The CFPB determined that

The California Department of Business Oversight (“DBO”) on October 25 published a regulatory proposal to “modernize” the California Financing Law (“CFL”) licensing process. To do so, the DBO proposed amending existing licensing rules to transition all licensees onto the Nationwide Multistate Licensing System (“NMLS”). According to the notice of rulemaking, today many CFL licensees

On September 25, California Assembly Bill 539 was presented to the Governor for signing. The Bill would prohibit licensees of the California Financing Law (CFL) from charging an interest rate greater than 36% plus the applicable Federal Funds Rate on consumer loans of at least $2,500, but less than $10,000. Currently the CFL does not

Rhode Island has amended its electronic money transfer law to require state licensing for certain entities providing cryptocurrency or “virtual currency”-related services. Specifically, entities that maintain “control of virtual currency or transactions in virtual currency on behalf of others” will need to become “currency transmission” licensees. An entity controls virtual currency if it has “the

On July 25, the Consumer Financial Protection Bureau released an Advance Notice of Proposed Rulemaking (“ANPR”) asking for the mortgage industry’s opinion on the scheduled expiration of a provision in its Ability to Repay/Qualified Mortgage Rule (“Rule”), commonly known as the “QM patch.” The QM patch allows certain mortgage loans that are eligible for purchase

The Conference of State Bank Supervisors (“CSBS”) announced on June 24 that 23 states have joined a multistate agreement to standardize their licensing process for money services businesses (“MSBs”), such as money transmitters. The agreement centralizes the review of common licensing requirements, such as a MSBs’ “business plan; direct and indirect owners, including background checks;

On May 29, the Consumer Financial Protection Bureau announced a settlement with BSI Financial Services, a Texas-based mortgage servicer. Acting as a reminder to mortgage servicers of the importance of maintaining rigorous information management systems, the CFPB alleged BSI violated the Consumer Financial Protection Act of 2010, the Real Estate Settlement Procedures Act, and the

On April 29, New Jersey’s governor signed into law bill A4997, known as the Mortgage Servicers Licensing Act. As the title indicates, the Act creates a licensing regime for servicers of residential mortgage loans secured by real property within New Jersey. As with many state licensing regimes, the Act exempts most banks and

The governors of Virginia and South Dakota have each signed a bill – HB 2690 and HB 1032, respectively – that moves the state’s licensing of money transmitters to the National Multistate Licensing System (“NMLS”). Both bills become effective on July 1, 2019. In addition to moving the money transmitter licensing process to NMLS,

On March 1, the Consumer Financial Protection Bureau released a report concerning mortgages made to members of the U.S. armed forces and veterans purchasing a first home.  It is part of a series of quarterly reports the CFPB will issue focusing on consumer credit trends.  This Quarterly Consumer Credit Trends report highlights trends among first-time