NEBRASKA COMBINES INSTALLMENT LOAN & SALES ACTS INTO SINGLE STATUTE
Effective October 1, 2025, Nebraska will combine the Installment Loan Act and the Installment Sales Act into a single statute: the Nebraska Installment Loan and Sales Act. Importantly, the state is not merging license types—installment loan and installment sales licenses will remain separate, with no new filings or action items required for current licensees. This update is purely statutory and aims to streamline the process without disrupting existing license holders.
Notable improvements include: modernized licensing procedures for installment loan licensees (removing publication and hearing steps), the introduction of branch licensing, alignment of net worth requirements across both license types, and annual reporting for installment sales companies. The Nebraska Department has advised that licensees should not notice any changes on October 1, but should monitor NMLS for flags or updates.
MASSACHUSETTS PHASING OUT CHECK SELLER & FOREIGN TRANSMITTAL LICENSES
Massachusetts is consolidating its money transmission regulatory framework under a single Money Transmitter License, eliminating the current Check Seller and Foreign Transmittal Agency licenses. All existing licensees must transition to the new license via NMLS between November 1 and December 31, 2025, to continue operating legally into 2026. The updated regime—passed under Chapter 312 of the Acts of 2024—broadens coverage to include domestic money transmission and imposes stricter financial and compliance requirements. Businesses that don’t complete the transition risk suspension or revocation by the Division of Banks.
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ILLINOIS COLLECTION AGENCY ACT MADE PERMANENT
Illinois Governor has signed SB 2457 into law, making the state’s Collection Agency Act permanent and introducing a suite of substantive amendments. The updated law preserves the core licensing framework while expanding exemptions for certain entities, refining reciprocity rules for out-of-state agencies, and strengthening the enforcement powers of the Illinois Department of Financial and Professional Regulation (IDFPR). These changes give IDFPR more authority to act against unlicensed or noncompliant collection activity, even as the state eases requirements for some firms. Agencies that previously relied on exemption interpretations—or operated without a clear licensing position—should reassess their status to avoid enforcement risk under the updated framework.
GEORGIA & NEBRASKA MODERNIZED MONEY TRANSMISSION LAWS
Georgia and Nebraska have enacted substantial updates to their money transmission statutes, aligning more closely with the Model Money Transmission Modernization Act (MTMA). Georgia’s changes, effective July 7, 2025, strengthen oversight of service providers, require licensees to maintain detailed vendor documentation, and mandate quarterly and annual reporting through NMLS. Nebraska’s LB 474, effective October 1, 2025, raises licensing fees and financial standards, clarifies exemption categories, and expands permissible investment options. Both states now enforce stricter audit readiness and regulatory expectations. Multistate licensees should revisit contracts, net worth thresholds, and reporting processes to ensure compliance.
CFPB RECONSIDERING WHO COUNTS AS A “LARGER PARTICIPANT”
The CFPB has released advance notices of proposed rulemaking that could change how it defines “larger participants” in several markets, including debt collection, money transmission, auto finance, and consumer reporting. These definitions determine which entities fall under the Bureau’s supervisory authority. For the debt collection industry, the CFPB is re-evaluating whether the current $10 million annual receipts threshold is appropriate, especially in light of consolidation and updated SBA standards. For money transmitters, it is considering increasing the transaction threshold from one million to 10 million. Any adjustment could mean that more mid-size and previously unregulated companies will be subject to federal supervision, examinations, and increased reporting expectations.
PENNSYLVANIA NOW REQUIRES LICENSE FOR VIRTUAL CURRENCY TRANSMISSION
Effective August 26, 2025, Pennsylvania will formally require a Money Transmitter License for any person or entity transmitting virtual currency for a fee or on behalf of another individual. This change, enacted under Act 7, amends the state’s Money Transmitter Act and replaces the prior Virtual Currency Statement of Policy (VCSOP), which will be rescinded on the same date. Businesses engaged in crypto transmission should already be licensed or cease operations, as there will be no grace period. Applications must be submitted via NMLS. Firms should review the updated licensing law and consult legal counsel to assess applicability and ensure full compliance.
BLOG POST
WHAT REGULATORS MAY EXPECT YOU TO KNOW ABOUT AI IN COLLECTIONS
AI tools are transforming how collection agencies manage operations, but with that innovation comes rising scrutiny. In this article, Leslie Bender, Senior Counsel at Eversheds Sutherland, outlines what regulators are beginning to ask during licensing renewals and exams, including how agencies use AI, what oversight controls are in place, and how consumer data is handled. From explainability and auditability to staff training and vendor risk, this piece equips readers with a practical compliance lens for today’s evolving tech environment.
Click here to read the full article and prepare for AI-related regulatory expectations.
MASSACHUSETTS “JUNK FEE” RULE TAKES EFFECT SEPTEMBER 2
Massachusetts has released guidance on its new “junk fee” rule, requiring all-in price disclosures and regulating subscription terms and trial offers. The rule aims to eliminate hidden charges and aligns with the FTC’s broader push for fee transparency. Financial services firms, lenders, and mortgage providers offering subscription-based products or services in the state should review these new disclosure obligations and update their pricing displays accordingly.
BILL TARGETS OFFSHORING AND AI IN CUSTOMER SERVICE
A bipartisan bill—the Keep Call Centers in America Act of 2025—has been introduced in Congress to discourage offshoring of call centers and mandate transparency around AI use in customer service. The proposed legislation would restrict federal grants and loans for companies that move operations overseas or rely heavily on AI without disclosing it. It also requires businesses to inform consumers when AI is used and to transfer them to a U.S.-based human agent upon request. If passed, this bill could significantly impact how financial service firms manage their customer support functions. Businesses with large customer service teams or automation strategies should keep this one on their radar.
WISCONSIN CRYPTO KIOSKS TARGETED WITH NEW LICENSING AND FRAUD RULES
Wisconsin lawmakers have introduced twin bills—SB 386 and AB 384—to bring the state’s 582 cryptocurrency kiosks under tighter regulatory oversight. The legislation would require kiosk operators to obtain a money transmitter license and implement strict consumer protection measures, including identity verification, fraud warnings, transaction limits, and refund obligations for scam victims. The move comes in response to a 99% spike in crypto ATM-related fraud, with losses totaling $247 million in 2024, according to FinCEN. If enacted, the law would limit daily transactions to $1,000 and cap fees at 3%, placing significant operational constraints on kiosk providers. This trend mirrors actions in other jurisdictions and could set a precedent for state-level crypto licensing and compliance across the U.S.
COMPANY FINED $2M OVER PHISHING BREACH
The New York Department of Financial Services (DFS) has issued a $2 million penalty against Healthplex, Inc. following a phishing incident that exposed data for more than 345,000 individuals. A single employee click gave attackers access to thousands of unsecured emails, highlighting a series of compliance failures including lack of multi-factor authentication (MFA), absent data retention policies, and delayed breach notification. DFS found multiple violations of its cybersecurity regulation, ranging from inadequate controls to late reporting and false annual certifications. The case reinforces DFS’s message that cybersecurity lapses will lead to swift and costly enforcement.
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RHODE ISLAND CYBERSECURITY RULES FOR FINANCIAL LICENSEES
Rhode Island has enacted Senate Bill 603, establishing comprehensive cybersecurity standards for financial institutions licensed by the Department of Business Regulation. If you manage a licensed financial or fintech firm operating in Rhode Island, you must now maintain a written information security program, conduct risk assessments, implement safeguards like multi-factor authentication and encryption, and perform annual penetration testing plus biannual vulnerability scans. The law also imposes a strict data retention limit, requiring customer data to be securely destroyed within two years unless otherwise permitted, and requires notification to regulators within three business days after a qualifying security event.
NY BILL PROPOSES 0.2% TAX ON CRYPTO TRANSACTIONS
A new bill introduced in the New York State Assembly would impose a 0.2% excise tax on all sales and transfers of digital assets—including cryptocurrencies and NFTs—beginning September 1, if passed. Bill 8966 aims to generate tax revenue from one of the nation’s busiest crypto markets. The measure would apply to virtual currencies, digital coins, non-fungible tokens, and similar assets, potentially increasing compliance burdens for exchanges, traders, and digital finance platforms operating in or servicing New York. With the state already home to one of the country’s most complex licensing regimes for digital assets, this bill could represent another layer of regulatory responsibility for crypto-focused businesses.
SEC ISSUES GUIDANCE ON LIQUID STAKING
The Securities and Exchange Commission (SEC) has clarified that certain “liquid staking” activities—where crypto holders deposit assets with a third party and receive tradable tokens in return—do not automatically trigger securities registration requirements. The guidance applies only when these activities do not meet the definition of an investment contract under federal securities laws. For fintechs and money transmitters operating in the crypto or DeFi space, this decision may reduce registration burdens—but only if structured carefully to meet the outlined criteria. Firms should still perform rigorous internal reviews and legal evaluations before marketing or expanding token-based services, especially if operating under state-level money transmission licenses or trust charters.
VIRTUAL SUGGESTION BOX
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COURT CLEARS WAY FOR CFPB MASS LAYOFFS—AND A REVAMPED RULEMAKING AGENDA
A federal appeals court has allowed the CFPB to proceed with plans to lay off the majority of its workforce, possibly reducing the agency from approximately 1,700 employees to around 200. The D.C. Circuit Court ruled that employment-related claims must go through the Civil Service Reform Act’s specialized process, affirming that the previous injunction blocking the layoffs was no longer valid. This move may significantly constrain the Bureau’s capacity to enforce consumer financial protections. At the same time, the CFPB released its semiannual Unified Rulemaking Agenda, which outlines 24 upcoming rulemaking and rescission initiatives, including updates to Regulation X (mortgage servicing), Regulation E (remittance transfers), and data transparency efforts. Firms across the industry should monitor these developments closely as they may signal both scaling back in enforcement and new regulatory expectations ahead.
BLOG POST
LICENSE-READY FROM DAY 1: DEBT COLLECTION STARTUP GUIDE
Launching a debt collection business is more than building a dialer and hiring agents—it starts with navigating a fragmented regulatory environment. This article breaks down the critical licensing, bonding, and operational requirements that every new collection agency, whether fintech or traditional, must tackle before launch. It covers everything from foreign qualification and municipal permits to vendor oversight and automation safeguards, helping teams avoid delays and compliance missteps. With regulators offering little leeway to first-timers, being license-ready from day one is essential.
Read the full article to build your launch roadmap.
OREGON TELEMARKETING RULES TIGHTEN, WITH DEBT COLLECTION EXEMPTIONS
Oregon has enacted HB 3865, a new law effective July 24, 2025, that significantly updates its telephone solicitation regulations. The law shortens calling hours by one hour, now banning outreach after 8 p.m., and broadens the definition of solicitation to include text messages. It also limits unsolicited contact to no more than three attempts in a 24-hour period, unless an established business relationship exists. Automatic dialing devices must now offer opt-outs and disconnect promptly—though debt collectors, debt buyers, and collection agencies are carved out from some of these requirements, including the opt-out mandate. The law reflects Oregon’s push for greater consumer privacy while acknowledging operational needs in debt recovery.
FLORIDA DEFAULT INTEREST BILL FAILS IN COMMITTEE
A Florida bill that would have added new notice and documentation requirements for lenders has failed to advance, but it signals potential future shifts. SB 392 would have clarified mandatory annual loan statements and required a written notice of default before collecting default interest. It also would have introduced new responsibilities for both assigning and assignee lenders, including providing loan history and balance change reports upon borrower request. The bill’s retroactive application raised compliance concerns across the lending industry. Although it died in committee this session, the bill may return when the Senate reconvenes in 2026. Lenders operating in Florida should continue to monitor for reintroduction.
This information is not intended to be, nor is it, legal advice. It is intended for information purposes only. We make no warranty, express or implied, as to the accuracy or reliability of this information. We are not attorneys. You must retain your own attorney to receive legal advice. While Cornerstone strives to provide the most current and accurate state licensing information, the responsibility for any decision related to state licensing or agency compliance is solely yours.
