# Year-End Licensing Checklist & 2026 Regulatory Outlook > This session discusses the year-end licensing checklist and the regulatory outlook for 2026, focusing on the challenges and considerations for financial services companies during the busy license renewal season. Panelists include experts from Cornerstone Licensing and Hudson Cook LLP, providing insights for compliance personnel and decision makers. Recorded: 2026-08-17 | Runtime: 59 min ## Key takeaways - Year-end is a critical time for financial services companies to re-evaluate their licensing and regulatory obligations. - Companies should start the renewal process early to avoid issues such as locked accounts or new state requirements. - Small changes in business activities may trigger the need for additional licenses, making it important to review licensing profiles annually. - States are likely to increase regulation in response to industry innovations, particularly in areas like student loan servicing and buy now pay later products. - Staying informed through trade associations and newsletters is crucial for anticipating regulatory changes and maintaining compliance. ## Transcript Hey everybody, good morning, good afternoon, wherever you are. My name is Joel Blackburn with Cornerstone Licensing and we are thrilled to have you here on this webinar here in the thick of license renewal season. We are it's a busy season for all of us in the financial services industry. And so we thought it'd be a good time to get everybody together, get this panel of experts to answer your questions and to give you some things to think about as decision makers, as compliance personnel here on the eve of a brand new year. 2025 has been pretty insane for all of us and we're gonna maybe peek into the crystal ball at 2026 and see what this next year might hold for us too. But let me get us started. You know we are we're going to both address some licensing and some regulatory things as we go. And just we want your questions. So please drop them in the chat. We will get to as many of them as we can but please don't be shy. Let me introduce our panel today. First of all, Chuck Dodge is a partner at Hudson Cook LLP where he advises creditors, servicers, debt buyers, and collectors on consumer credit and debt collection regulatory matters. He leads the firm's federal and state debt collection practice, helping clients develop effective compliance programs and address issues related to credit enforcement and debt recovery. He is a member of the Maryland and Maine State Bar Association associations and the ABA's consumer financial services committee. Chuck earned his law degree from the University of Maryland School of Law and holds dual bachelor degrees in economics with honors and Spanish from Lafayette College. Anastasia Canton is also a partner at Hudson Cook LLP where she advises financial institutions, lenders, servicesers, collection agencies, and investor clients on consumer credit and small business finance laws. She helps organizations develop compliant credit programs, navigate servicing and debt collection regulations, and respond to federal and state enforcement actions. Anastasia also represents industry interest in high-profile consumer credit enforcement actions and provides strategic counsel on evolving regulatory trends impacting debt collection and collateral recovery. She serves as vice chair of the ABA's personal property finance subcommittee and is a member of the receivables management association. Anastasia earned her JD Magnaumlotti from Tainan University Law School and holds a BA in public policy studies and history from Duke University. Christy Young Barger is the senior director of licensing at Cornerstone. She's been with the company this month will be 20 years. Correct, Christy? Christy Barger: Yes, that is correct. That is a long time. Long time. Christy is a trusted leader in guiding clients through complex licensing, compliance, and business expansion challenges. Her expertise and proactive approach to state regulations ensure clients stay ahead and helps drive their long-term success. As mentioned, we're going to be talking about some regulatory and compliance matters. So, we need to chat or at least mention this legal disclaimer. This information is not intended to be legal advice and may not be used as legal advice. Though some of today's presenters are attorneys, attending this webinar does not create an attorney-client relationship between the attorneys and the attendees. Legal advice must be tailored to the specific circumstances of each case. Every effort has been made to assure this information is up to date. It is not intended to be a full and exhaustive explanation of the law in any area. Christy Barger: However, nor should it be used to replace the advice of your own legal counsel. All right, let's get started. As I mentioned, please ask questions as we go. We'll get to as many of them as we can. Great to see. I see we've got a full house today. Really good to see. All right. We, at Cornerstone are in the midst of renewal season. So, what does effective year-end readiness look like for financial services companies and why is this time of year particularly important for licensing and regulatory obligations? Christie, I think this is pretty custom fit for you. Yeah, absolutely. Christy Barger: Thank you. So, year end sneaks up on us. I mean, we were just planning summer vacations and now we're talking about year end and Thanksgiving's next week and Christmas is coming. So, there's a shortened time frame that we're kind of working in right now where there are a lot of things due. All of the NMLS states, for example, they renew by 12:31. Let's not forget the ones outside of the NMLS like Florida who also renews on December 30th. And if you get approved before, you know, the 30th of December, you have to turn around and renew it. So, there's just a lot of things going on that you have to keep up with. And, states change their requirements. They'll add something new that wasn't there last year and you've got to scramble to get that together. You've got your business may have planned throughout the year and while we all try to remember exactly you know how we've submitted licenses and what activities we're reporting when you see those boxes on the NMLS where you're checking off your activities that sometimes is a trigger going oh yeah I did start doing that earlier in the year and that could mean additional requirements or maybe a brand new license that you hadn't thought about. So, lot of moving parts. You try to get going early. Christy Barger: Some of the states will allow you to submit pretty early. So, you know, October is the time we should have been thinking and talking about this and now we're like in the middle of it and, the clock's ticking. Chuck Dodge: So, Christie, based on that, then what do you see happen with companies that wait too long to start addressing the renewal steps of the process? Christy Barger: So, some of them can even be outside of the licensing control. As we get closer to the end of the year, all these licenses are due on the NMLS. There's thousands of them. Every company has a login, every control person has a login and password. Let's say your pass your account's locked for some reason and then you need to reset your password. You're on hold with the NMLS for two or four hours. I've heard that happening. And especially as we get closer to that the 12:31 deadline, the phone may not even pick up. I mean, they're just they have a influx of calls and so that can really be a real problem if you can't get in there to renew your license over something over simple as a password. The new requirements that kind of pop up every year. That's another thing at this time where you know, if you don't know it's there and you have to pull something together at the last minute, that's going to take time. I think a couple of the years the states this year have add had have added in like an activity report, a collection activity report. And while obviously that's data that you have, it's probably not data in the format that they're looking for. And so you have to go find that internally and of course you need it yesterday. And so it just gets really stressful when those things kind of start popping up as we get closer to the end of the year. Chuck Dodge: Yeah. But the overall moral of the story I'm hearing from you is, you know, I know from our perspective, we're trying to get our clients renewed as quickly as possible. But just in general to anybody who's listening, you would say like the sooner the better. Like don't wait until the last minute to start that process. Christy Barger: Yep. Don't wait until the last minute. Absolutely not. And another thing too is, you know, let's say you submit your renewal and you think everything's there and then they have a question and they throw a deficiency. Maybe nothing at all, but deficiencies happen and they're only going to give you a short period of time to address that. And so there's another deadline that's thrown on you in the middle of the craziness of all the other states. So timing is everything. Chuck Dodge: Yeah, that's great. So, sorry. I just want to Christie, we've run into before where the states won't start their counting of days for their response times unless they have what they consider a complete application or a complete renewal application. So, not answering that can be can slow you down in terms of getting the renewal process started, let alone finished on time. Right. Absolutely. Absolutely. That's great. Thanks for that, Chuck. Backing up one step, so get going a little bit higher level. Why is year end a good time to just re-evaluate your licensing overall? And what should this re-evaluation entail? You know, we're kind of prepping for a brand new year. You may have your goals for 26, but why should somebody listening to this here in November start saying, "Okay, why do I have the licenses I have and why do I not have the licenses I don't have? Why is now a good time to be thinking about that?" Kind of goes back to when you start checking those boxes in the NMLS, it's going to remind you that, oh, we are doing that now, forgot about that. You know, and on top of that, there's companies changing structures at this time of year. So it's just you're doing your budgets and you know state fees change and while you can't know about all of those, you've kind of got to think ahead to budget for next year. So it's just your, you know, you're doing your year end for your company and licensing is a big part of that. Chuck Dodge: Yeah. Anastasia, go ahead. Anastasia Canton: Yeah, to Christy's point about checking those boxes and being reminded of what you did this past year, even small tweaks, and I'm coming at this from a regulatory compliance perspective, even small tweaks in what you've done over the last year, you may have unwittingly found yourself in licensable activity. So, you know, going from being a pre-default servicer only to let's say you did take over a portfolio that some of the accounts were in default. So, that could trigger additional licenses in states that you're in. Other things to consider like if you're acquiring products that you've never serviced before or you've never collected on before as part of a year-end transaction, you know, trying to get deals closed by the end of the year. You could find yourself meeting some sort of, let's say you've never serviced mortgage loans. Some of those mortgage loan licensing laws apply even if you purchase the mortgage loan and you own it and you're servicing it. So you may not have ever had that in your portfolio before, but now you might need a mortgage loan servicer license. And then another like potential consideration are changes in dollar thresholds. And I don't know if this is so much a year-end evaluation, maybe it's a, you know, looking ahead type of thing, like, as states change their dollar thresholds for when their laws apply. That can result in you needing a license. Anastasia Canton: Like one, I think a really good example of this is a couple years ago, North Carolina revised their consumer finance act, which is their lending law. They raised the dollar threshold and they also added servicing in their definition of licensable activity. And so, you know, if you're in, you know, doing business in North Carolina, keeping an eye on that type of legislation as it moves and as it becomes effective is very important when you're looking ahead to future planning. I think I probably jumped ahead in our agenda, but you know, I like how Christy teed it up with like looking at your license renewals and oh, I did start doing this. And I think that can start an important conversation in your organization about what you want your licensing profile to look like. And Joel, you mentioned goals. Anastasia Canton: One of the things that the great might hand down from the top is we have goals for next year. We want to expand capacity or we want to try to pick up new products and so attending to those and reviewing licensing at that time when you figure out our model might be different next year from what we did this year. And the end of the year is a time for expressing those goals and setting some either, you know, budget goals so we want to produce this much revenue either based on what we have or what we want to add. But also just kind of resetting the business to think about this year we may be tired of it's finished and now we're getting on to next year. So the kind of advanced planning and in conjunction with that, you look at pre-filed bills. What are the states doing? We're not seeing much of that yet, but where the states kind of preview what they're thinking about for the next year. And then what sort of enforcement actions came down that would suggest that we need to do something differently, not because our business model changed, but because the law changed based on, you know, I'm thinking of a recent settlement with a debt collector where the investigations came out of an investigation of a lender. And then they went for the debt collectors for collecting on a product they shouldn't have been collecting on without a license or at all. Anastasia Canton: And so you kind of you get to take a look back and see what happened this year that might change the way we do things next year. And end of the year is a pretty convenient time to do that and start to empower people to track different, you know, different legislation or different litigation or enforcement trends so that we hit the ground running in the start of new year when people have energy back from their holidays. Yeah, that's great, Chuck. And you touched on something I just want to briefly kind of take a side car, too. How much did 2025 surprise you in terms of the states movement? Because I mean, I think when Trump 2.0 happened, like all of a sudden with the deregulation, there was this expectation that there was just going to be a deluge of state level activity. Was it what you expected it to be or was it less or more? Chuck Dodge: I would definitely say at least in the beginning the states got a slow start for sure. I think that they were caught off guard by how quickly the administration moved to not only take, you know, pause agency actions, but also to shut down supervision, which did not happen during the first Trump administration. We did not see a total halt in supervisory activity. And then on top of that, close open and active investigations. Like I think the states just did not realize that it would happen that quickly and to that extent. But a lot of them had an infrastructure in place to start moving like states like Pennsylvania and California, Virginia had created these sort of mini CFPBs or consumer protection units within the state. So they were ready to act when the federal pullback occurred but again it happens so quickly. But I think what we've seen as the years gone on is the players that you would expect have really ramped things up. So New York, California, Massachusetts, Connecticut, New York in particular has like picked up a lawsuit that the CFPB had completely dropped. They came in and filed the exact same one against the bank. So I think we're going to continue to see that. But if I say I would anything that surprised me was kind of how long it took the states to ramp up. Chuck Dodge: I think as the new legislative sessions come into focus, we're going to see a lot more state consumer protection activity in the legislative branches of the states. And then potentially also, you know, looking at appropriations and are we adequately funding our state AG's office? Are we adequately funding our credit regulator, you know, our department of financial regulation or commissioner of banks or whatever it's called in the state? Do they have the resources they need to take action? And I'll take one tangent about Oregon, which shouldn't surprise anyone, but they held a meeting recently in their legislature where they brought in the AG and they brought in the Department of Financial Regulation, which is their licensing regulator, and asked them, do you have what you need? And what more can we do to support you and will you report to us when and if you feel like you need something based on the federal pullback? And it was a really interesting meeting to hear them talk about the AG in particular, how they're ramping up enforcement. They've like almost doubled their capacity. And then to hear the DFR talk about that they were extremely knowledgeable and very aware of the laws they enforce and very aware of their limitations and they discuss how they work with the AG. Chuck Dodge: So I think we can expect more of that at the state level in the next year, but definitely it was a slow uptick. Anastasia Canton: And Chuck may have other thoughts too on things he's seen. I was going to add some to agree with you for the most part, but also just to kind of add a couple slightly different points there. The what we see consistently is the states tend to be reactive. They don't have the same kind of funding that CFPB no longer has, but it used to have a pretty limitless budget that would let it explore all the avenues of investigation and credential regulation that it wanted to. The states don't quite have that. So, they tend to be reactive to consumer complaints. Business complaints if they you know if you get a tattletail or whistleblower I'm sorry saying that this company's doing this without a license you should look into them. And so with limited resources they go after that and not every state has the capacity to add to the resources the budget resources that the regulators have. One thing I was surprised this year we didn't see as much is a coordinated effort and maybe that's coming next year. You know the presidential administration's four years long so it could be that the states will get together and start to think about trends that they don't like to see and start doing some enforcement work together, which we've seen in the past. Anastasia Canton: But there wasn't anything that comes to mind for today that started in 2025 sort of as a reaction to the pullback in federal enforcement where we saw the states kind of working together towards an end of investigating and running to ground something that was, you know, I'm being vague, but I don't have a specific issue of mine, but running something to ground that was troubling them that the bureau might otherwise have led the charge on. And in the past, we've seen the bureau would start something and the states would, you know, state a be, yeah, I like that. We're going to be part of this action as well. So, not as much that, but doesn't mean it's not coming. It just means it hasn't happened. As far as I'm concerned, it hasn't happened yet. So, but no real surprises. I think not that we're pleased at the outcome, but we and everybody else sort of predicted that with the pullback in federal enforcement and federal legislating and deregulation as the goal that the states would sort of pick up the pace. And a bunch of states and including and especially the ones Chuck mentioned are sort of leading the charge on that and paying closer attention you know undeterred by what's happening in the federal government. They're going to protect their citizens. Anastasia Canton: So, and I'll the only thing I will add the places where I have seen I've been a little surprised to see a state uptick are licensing to the to this conversation. It's been kind of surprising and even during Trump 1.0 and over the last, you know, during the Biden administration, we did not see states really being aggressive about clients or companies not having the licenses that the state thinks they need to have. And we've seen more and more of that. We've also seen and like one state that surprised me, Georgia. I'll give that as an example. But we've also seen more like ticky tech issues arising from exams. So whereas before you submitted all your documentation to the examiner, they signed off on it, no issues. Now they're coming back, we've noticed, with more taking issue with things that they had previously not taken issue with. So things that are coming up in the exam, which is like a reminder that to the extent you're a supervised entity, anything that you're submitting to the regulator, you can't count on the fact that they may have been okay with it the last time that you had an exam because I think that they're all I think a little more concerned about supervision now that the bureau has basically shut down supervision and has proposed to significantly reduce its supervision if or when it ever begins supervising entities again. Chuck Dodge: That's great advice. Thank you both for that and thanks for that. I think looking back is going to give us a pretty good indicator of what 2026 could look like. So that's a good kind of preamble to later in our discussion. Our buddy Michael Lamm who you know handles a lot of the M&A activity at least in the arm industry. I assume he is quite busy these days just given the nature of the industry. Talk to me a little bit about you know if a company is getting ready to either acquire or be acquired or merge, what effect does that have on you know the 1231 renewals coming up on the beginning of 2026? Like, can you just basically say, 'Hey, we're, you know, we're getting bought, so we can put this off to the side or what impact is M&A activity going to happen on year-end renewals? Chuck Dodge: I'll start with that one. A ton. It will have a lot to do with the year-end renewals. So, any with any type of change, it's very time-sensitive. Some of the states want prior notice before it even happens. After that they want, you know, they start using words immediate. If there's a relic license involved, let's say it's 100% acquisition, Colorado gives you 30 days to get that new application in, not sent, in their hands by the 30th day, in order to not get a cease and desist order and stop your collections. So every little change that could happen and a lot of that happens this time of year because people are retiring people are you know jumping to another employment. So those have to be worked at the same times as the renewals are being worked. Just because you're having to relic in a state doesn't mean you don't have to file the renewal as well. Chuck Dodge: So you could be making two filings to the same state with the same information basically, but you still have to do that pay that fee to keep that license there and in place while the new one's being processed. You know, this time of year a lot of the states kind of shift their focus on just simply to renewals and so they're only looking at renewal submissions. If you've got an initial submission, it's probably going to sit there extra long. So again, you've just have to do you have to spin the plates. Lots of filings at the same time. Maybe the same information you would feel it's a duplicate. You know, there's more fees that way, but you have to do that in order to keep your licenses good as you're going through the change process. Christy Barger: And Chrissy, that can be impactful, right? If you don't do that and you and they are so the regulators are so focused on renewal, then that can put a hitch in your plans to merge at a certain time or be acquired and the acquirer can it can slow your time frame down. And we know from experience business people don't like that when that happens. So it's a kind of red exclamation point to continue right to continue that whatever I need to do to get renewed on time and to watch the both the closing deadline for your transaction but also your renewal and new filing deadlines to make sure all that's happening at the same at the on the right basis. Christy Barger: And I have a question for you because I don't know the answer to this but it's something I would recommend based on what you're saying. If I'm doing a renewal, and I know that I have a transaction pending and we've cleared everything, so we have a letter of intent, we have everything is signed and or almost signed, I guess, is we're working through due diligence and everything. You recommend putting like a cover letter if or something to that effect together with our renewal to say, "By the way, you know, on February 1st, we're going to be sending you a pile of information about an acquisition that we're either making or we're being acquired. We have some change of control information coming to you, so just so you know, or a new application." Do you recommend that or is that useless because it just goes in a file, nobody's looking at it? Chuck Dodge: Absolutely. The sooner you can tell a date, the better. Anytime a company is looking to go through an acquisition or an officer change or manager change, as soon as you start looking at that letter of intent, I suggest sending out a letter to the states where you're licensed. You may keep it simple. Just say, "Hey, we're going to be acquired in the near future. We anticipate officer ownership manager changes." while we are still go working through that with legal don't know all the details please know it's coming and as soon as we do know we will submit the required modifications additions new licensing but the sooner you can let the state know that's coming down the pipe it's very important to do so and one thing a lot of people push back on that and was like well I don't you know I don't know if it's going to happen I don't want it to get out those letters stay with the state they're not posting them anywhere so nobody's going to see that's going on and let's say the deal falls through because obviously they do it's a simple letter to the state going never mind deal fell through nothing's changing thank you for my you know thank you for your time u it's very simple to rectify that if there is a cease acquisition that happens and the notification doesn't have to name the potential acquirer right you just have to say there's something potentially happening we're just letting you know that we're going to have some potentially some filings by x date but we don't have to name names so that the confidentiality I know is a big deal when we do those things. So I imagine with you see the same thing. Yep. Very vague. It's, you know, of course the state wants to know as much as possible, but at that point you don't know what's going to happen. So vague changes are coming. I don't know what those are, but we're telling you they're coming. Hold your horses. We'll tell you what we know. Exactly. Just a reminder to the audience, you are more than welcome to ask questions. Please drop those in the chat. We'll do our best to get to them. Chuck Dodge: Chuck and Anastasia, specifically talking about the legal and regulatory aspects of renewals, what risks do you see appear at this time of year kind of uniquely that you don't see show up, you know, in May or whatever? Anastasia Canton: You can go for sure. Well, primarily for me it's the readiness thing. So, when I think about kind of what Chrissy was talking about earlier, through the course of the year and this is really staff dependent, right? So you have people in charge of every little thing. Everybody's is overworked because everybody tries to run lean. We do the same thing. So I'm not casting aspersions. I'm just identifying what we go through. But the more proactively you manage your documentation, the renewal process and everything throughout the course of the year, the better you prepared you are to just hit send when it's time to make those filings. We have people who are great at managing close work like that at our place. We don't have filings like that because we're not licensed as a law firm. But having somebody ready to go to understand that in the 12 states where we're licensed, we need to submit, you know, any changes to our customer communications together with our renewal or any of those renewal things. Calculation of fees when you have a volume based, for example, volume based fees with a notification or registration that you're prepared to do those things because you saw them coming. So it's kind of being caught flatfooted when this thing is coming. And you know, we all have reasons why we haven't done the things. I'm looking in the mirror here. Anastasia Canton: Think we haven't done these things because we're doing other things, but you don't get a break like we talked about earlier with the deadlines. Have to get these things filed. Otherwise, you're going to put a monkey wrench in the works when it comes to either just keeping your license fluid through the next year or if you're doing a merger and acquisition, not being able to keep up with that because you haven't done the other filings to keep yourself in good standing. Chuck Dodge: Yeah, I don't think I have anything to add there. Well, maybe just one thing which is like to the extent you're reporting on things and you come you another reason to start early to Chrissy's point to the extent you're reporting on things and you realize I we should have filed you know we had a change in our main office location. We should have updated them at the time of that or just after that. Being able to you know huddle with your compliance folks or your council to come up with like a good way a good story to tell along with that if there is a problem with your renewal I think is just another reason to get started early in case there are issues that you come across as you're filling out the renewal paperwork. It actually says reminds me that there are several states where you have to register all your collectors aliases if you do desk names or aliases and you and but they don't always require Minnesota comes to mind. They don't require that you update that in real time but if you have any attrition where people leave or if you grow the business and people and you do some hiring those have to get submitted at the end of the year. So tracking those in real time and making sure that the list is up to date means that at the time it's ready to submit I just have to do a quick check against my current employees to make sure that they're listed and then submit that. Otherwise, you're starting from scratch. You know, where's last year's list? What did I tell them? What happened this year? Who's still here and who's not? That can be cumbersome and burdensome, but it's much easier to manage in real time when as part of your HR process. We hire this person to sign them a desk name if they're not going to use their real name, and then that becomes a list that is a living thing that you can turn in at the end of the year. So, real time tracking of changes like that you know, you're going to have to report goes a long way to making this process a little bit less cumbersome and more efficient. Yeah. And some people have hundreds, maybe even thousands of collectors. So, it's not a quick list to scroll through. You're spending some time to get that thing right if it's you haven't been doing it throughout the year. Great. And just on that same theme, we're generally talking about state level requirements here, but is there anything on the federal level, either existing or new, that's going to affect the year-end renewals from the state level, or is this strictly just every state is making its rules, and that's kind of it? There's nothing on the federal level that really applies to year-end license renewals. I'm sort of focused on state stuff here. Because on the federal level, they shouldn't the changes at the federal level shouldn't necessarily trip a licensing, for example, a renewal obligation or a new license. With the exception potentially of the dollar thresholds, which we'll come back to a little bit, but you know, sometimes the truth and lending, well, I guess we won't come back to they'll take care of it real quick. Truth and lending non-mortgage and non-student loan thresholds change or can change every year. And so the Federal Reserve publishes that CFPB was doing that. We'll see who publishes it this year. But when that dollar thresholds up go up, a number of states base their licensing and the scope of regulation on those thresholds. So that's something to look out for. But usually, well actually they change a bunch of thresholds. There's a lot to watch for that because the states that are doing index based changes for fee permissions or deficiency balance collections sorry answers go ahead interest rates. Yeah. Right. Right. And deficiency. Yeah. Those changes can be impactful. But the other thing I would think about on this as I'm standing here trying to think through what happens not necessarily an impact of federal law changes but case law you know federal cases for example the true lender cases or for a while the Madden cases you know we're talking about interest rates where there may be a sea change in what we understand to be the you know the right to hold paper at a certain level without you know the right of an assignee of a national bank for example to hold paper where the interest rate is above a state threshold and whether we can continue to enforce that paper as it is or do we need a license to do that. Something like that can happen through the course of the year that it happens in the courts. It may or may not get hung up in appeals. A regulator may or may not have something to say about it, but that's something where the states aren't necessarily controlling that narrative. They have their things in place, but something else environmentally can happen that means we have to reexamine the state rules because of whatever that change is. Thanks, Chuck. We've got a question in the chat that kind of gets into how has NMLS changed and you know, are there changes leading up to 1231 if I'm understanding the question correctly? I know that the interface for NMLS has changed rather dramatically in the last year or so, but are any of you do any of you want to delve into any other changes with the platform and in maybe the way that renewals are handled within NMLS and just general the question was kind of requesting materials which we can perhaps provide after the webinar is over, but you know NMLS that I mean we could have a webinar just on that but do you want to talk maybe a little bit about some of the changes that have happened in the platform and maybe just some general guidelines on how to navigate that now that we're down to you know 45 days or so before the end of the year. Christy Barger: Yeah. So a couple things we have seen is, as we all mentioned, that some changes happened a few months ago in the NMLS. There's kind of an individual place now where individuals have to renew. I think of MLO that would be something that would have to go through an individual login where the company goes through another side of the portal for filing. You know, it's important to one of the, I think the biggest change that people get surprised by is an actual state requirement, not really the process through the NMLS. It's, oh now we have to do this report that was never required before and it's going to take, you know, a long time to gather the information. And so kind of knowing the whole looking across all of your licenses that renew at the end of the year, don't do it one by one. That's something our team really works hard on is they look at the year end as a whole and so obviously a lot of the information can be used for multiple states especially through the NMLS. And people think, oh well I just, if I do this once I'm going to be good. Then those each state individual specific requirements is what holds a lot of people up and surprises people that those are out there and they're like, 'Oh, we didn't have to do that last year or oh, my collector list doesn't isn't formatted that way.' And it's just all those little things can just take time which pushes you up to a deadline and then what if the NMLS gets locked out and you know, you've lost time there. So, that's more of a thing for the changes that we see as the requirements, not necessarily how the NMLS is doing it. But you know, what each state's going to want for that specific renewal. Christy Barger: Our, you know, is fingerprints expired? Some states require you to do fingerprints every three years. So, you know, this time of year, we all like to take vacations and we travel and are off seeing family, but you have to do your fingerprints by 12:31 in order to renew. But if you're in another country, how do I do that? So, it's timing and knowing what's required across all of the states, not just one state at a time. It's very important. The other great call to not procrastinating because I don't think anybody wants to be chasing down fingerprints on December 27th or anything like that. So, good reminder there. And thanks for the question. Chuck Dodge: You talked about, sorry, Joel. Just real quick with Christy. Another reason to sort of track NMLS and what they're doing because the states will furnish their changes to the system as they go. So, if a regulation changes and they need new information or different information, they'll put that up. So, being ready and tracking the NMLS for the states you're in and the licenses you hold and seeing what they require, you know, periodically through the year and then just as you're about to start your renewal process to see if anything's different. I think NMLS is a pretty solid system, but we've run into some, not in the actual licensing process, but the information process they have or for a period they had different information in different places and none of that information in some cases was reflected in a regulation or something on the state website. So, you're trying to figure out what is the most recent current version of this that I should be thinking about for the end of the year. And before renewal starts is the time to be asking those questions of NMLS before, like Christy said, you get on the phone and either nobody picks up or you'll be sitting there on hold for several hours waiting for somebody. So, sooner is better when it comes to kind of tracking that information. Chuck Dodge: And I'll just add to that, like you can be on top of all the laws and regulations, but at the end of the day, it's what the regulator decides they want. So, and they're gonna, they I think, I mean Christy, correct me if I'm wrong. I think they're going to put that on NMLS and maybe on their website. That's the best source for that. You're not going to always see that in like their, you know, their written rules. So it's very important to be on top of what NMLS is telling you to do. That's what we usually tell our clients. Like we can read the regs, we can tell you what the regulator says, we can tell you what the law says, but here's what the NMLS says, and that's probably the best source of truth if that's the licensing system used in the state. Yeah. Some states are better than others about telling you what they want and some states very quietly post changes and it's up to you to figure it out. But some states will do a memo or just kind of announce it on the website with a star next to it or a new flash, something like that. But some states you definitely get to find it for yourself. So, depends on how earnestly they want you to comply with their new requirement. That's great. Thank you guys. Another question that I think would be good to address. Now, have you seen or heard of any recent enforcement actions or regulatory activity in California targeting collection agencies since the latest rule changes went into effect? I'm trying to assess whether there has been any noticeable shift in how the DFBI is approaching oversight or compliance exams. Anastasia Canton: I can start with this one. I track state enforcement pretty closely and I have not seen anything in 2025 with DFPI and the collection license. But I also think that they maybe didn't have their funding wasn't great up until recently and now with their collection of the fees or they're starting to collect these exorbitant fees from some folks. I think we may see more from them. But I have not actually seen anything from them in 2025. And this could be a good jumping off point for the fees, but I don't know if Chuck or Christy have heard anything from DFPI. Certainly nothing published that I've seen. So, they may be working on investigations or they may be in exams starting to identify things they're going to want to prioritize in the coming year for enforcement, but I haven't seen anything published. So, or anecdotally haven't heard anything like that. Thank you. That's a good launching point as well because yesterday there was a memo sent out by both ACA and RMAI regarding the these new assessment fees that the FBI is using to fund their activity. Can you just speak quickly to, you know, the content of the memo and, you know, how any listeners who are licenses there should approach that memo in terms of their actions. I can take this one if nobody else wants it. So there's been a bunch of talk at especially at RMAI and ACA about this and so that their memo makes sense. Don't know if it's going to be effective, but there's some impact from solidarity in the complaint. And just for the benefit of any attendees who don't know what's happening out there, the DFBI has a $10 million budget for managing its collection agency licenses and it is wanting to it's wanting its process its fee generation to cover that entirely. So you have basically that $10 million split among the 12 or so hundred lenses under that statute. Maybe that might I might be wrong about that number. And while 60ish% and I'm repeating David Reed from REI, I don't think he's on here, but in case he hears about this is data we've gotten from him, but they're very proud of the fact that 60% or so of licenses are paying less than $250 for their license renewal at this point, but they're quietly not saying anything about this the couple of lenses who are going to pay over a million dollars in their assessment. And to give everyone kind of a baseline, the average license renewal or assessment is somewhere between $1,000 and $2,500, something like that. So the million dollars or half million, those who are paying exorbitant amounts, it's based on revenue. So this is a revenue from California collection specifically. So they're taking that $10 million and assigning it prata to lences based on your successful collection. So not a great model and lots to complain about. So the so what the licenses are what the recommendation was in the memo is send your payment because you have to otherwise you lose your license but send it with a letter that says you're doing this under protest because this system doesn't make a ton of sense and see if we can get the state's attention find your budget somewhere else there's lots of places to raise money it doesn't have to be from lences who you know by all accounts this isn't based on penalties this is just based on successful collections John do you fear based on the copycat nature of you know the regulators that other states are going to see the structure of how the DFPI does their fundraising and try and copy it. My concern for both sides of the sort of you know the lency and the license agency is if they do that you're going to find companies don't want to do this work anymore and so that's going to have a big impact on the system because if you can't afford basically to remain in business and be profitable to some point because somebody somewhere requires these companies to be profitable. If you're paying, you know, half million dollars to every state that has a license because the state thinks it's a great idea to raise funds exclusively from lences, that model comes apart. And the my sense is and I'm this is crystal ball stuff just taking a stab at it with those letters under protest and with the constant I think comments that the DFBI is going to be getting they're going to have to revisit this model and come up with something that makes more sense because if other state again if other states try to try to take this model on and share the burden of you know paying for a regulatory system that they didn't ask for among lences people are going to find some something else to do and that's Again, my biggest fear I guess of that is the impact on the credit and collection system because there is this and not to get too far into it but effective collections impacts credit availability, credit pricing. You know, if we can't if we don't have a place to offload debt to a debt buyer or to get help collecting it because we have a small collections team because nobody will do that work in the state, we can't collect it. The price of credit goes up. If we can't collect it and we start carrying bad debt, eventually our books are so bad that we either have to sell what we can asset wise and shut the business down and take one more sort of potential offramp for somebody who owns debt or needs debt collected. And the fewer players there are just the less it's better for everybody if there are more people doing this and there's some healthy competition for the work and keeping prices at a manageable level. And if this becomes the model for fee assessment for licences, especially in the collection and debt buying space, I don't see much future. I don't see much future for that model in particular in those states that might try to adopt it. So I hope not. I guess that's a very windy way of saying I hope that doesn't end up being the model. Anastasia Canton: Yeah, I expected that would be your ultimate answer. You can go ahead, Anastasia. Sorry. Wait, I was just going to say California is also unique in that this license is required of anyone who collects paper whether it's their own or someone else's unless they're exempt because they're bank or CFL license. So, that to me could be a potential line in the sand for other states that want to do something like this. It's just to me like a different type of license. And I think California maybe is in a position to extort a little more from these licenses than maybe another state that has just a third party collection license. It just applies a third party activity. But I'm just guessing here like we have no way to know. But that I think that could be you know we might not see Massachusetts take that position or Florida or another state that has a true third party license. Chuck Dodge: Great asterisk to that. Thank you for that, Anastasia. I'll just use this as an opportunity also to encourage our folks, and I know I see who's attending, and I know many of you are already doing this, but that's why the trade associations are so important. You know, it's not it doesn't always work, right? You're not always going to be able to get, you know, a regulator to change their approach or their rule. But like Chuck said, the solidarity matters. And so, you know, giving to the legislative funds, participating in events, letting legislators know how this actually affects your business, you know, those things really matter. And you know, the trade associations have had success because people speak up. So, you know, I would just say like get involved, show up, speak up. You know, if you're able to go to DC for the events, but you know, just participating in your RMAs, your MBAs, your MSBAs, your ACA, you know, just get involved in the associations because those things really do, you know, have an effect because otherwise these legislators may not realize the effects of some of the things that are coming across their desk. So, another great question. We received an email informing us that a limited scope examination of our company was being initiated by the Georgia Department of Banking and Finance. We had to submit our policies on AML, BSA, and IT information security. Chuck Dodge: They also said they're reviewing the call report, information submitted through NMLS, and any complaints received. Can you tell me what the examination team is looking for in the limited scope exam or is this just administrative to check some boxes? I'd love to suggest it's just administrative to check boxes, but it seems pretty specific. In particular, BSA AML policy for a company who I'm going to take a stab at this. Is if you're at a licensing webinar, you're not a bank. I would look at the BSA AML rules because as far as I know, and Anastasia or Chrissy, please correct me if I'm wrong. I don't think those apply yet to a non-bank. Those are federal statutes written for there's know your customer stuff. That's different from the BSA, anti-money laundering. It's good to have a policy, but the law doesn't apply. So, if you don't have the policy, I think it's fair to say we don't have that. We do have, you know, maybe old fact checks or something like that just make sure that we're not funding terrorist activities. But the that and the IT security, you know, data is very much on the minds of the state and federal government right now, data use and data protection. So, we've seen lots of enforcement this year and last year on that, even in states that don't typically run for consumer protection activity. Thinking of Texas in this case, the Texas AG is pursuing vehicle manufacturers in the last two years for the data that they track and sell based on where you take your car and you know how fast you drive and they're selling it to insurance companies and other people. So, and Texas doesn't like that. So, they've taken some action there. So, data use data protection stands out to me as one of the things that they're looking for in the IT security stuff. So, I would I mean you don't really have a choice but to comply with it. And then I'd recommend and Anastasia probably agree with this get some counsel to support you on the exam because if they're asking for things they shouldn't be asking for you may able to get some help resisting it. You know propriety information or confidential information you better conversation with the regulator just you know tell me why what are we after here and then they can also help explain why you might not have a BSA AML policy. Yeah, my instinct from government defense work is that if they're asking for something specific and targeted and it's a special inquiry, this is probably not just purely administrative. But again, I recommend talk to your council about it about the best way to handle it. You know, usually in the beginning, especially in the supervisory context, you want the council in the background. You don't want to come in lawyered up guns blazing. That makes you look like you have something to hide. But again, I would just consult with your council about the best strategy to move forward. One note about states probably more impactful than at the federal government level, but if something gets in somebody's craw at the state level, they can do something about it much more quickly than the federal government. But there's lots of anecdotes about why we have, for example, a HUD one settlement statement at a mortgage closing. That's because somebody in Congress got upset. It was I think it was the senator Proxmire, right Anastasia? I think this is Tim Mer's story but somebody got surprised by their closing costs at a mortgage closing and now we have respax and truth and lending act provisions there. So at the state level somebody somewhere may have had a family member u you know affected by something somebody did that wasn't regulated at the state level and now it's become part of everybody's problem. So th those things it I wouldn't underestimate the impact of personal experience at the state level impacting us as an industry because it happens. Yeah. Yeah. And in these credit, these like DFBI and commissioners and banks and those types of regulators, they don't have to run things at the chain the same way that like an AG's office would or the Bureau or the Federal Trade Commission. In my experience, they tend to be far less bureaucratic because they're not really supposed to be in an enforcement posture in most instances. So, like Chuck said, if they have an issue and they're worried about it and they don't like it, then they can kind of run with it in a supervisory context until potentially they find something. So, they have a little more leeway, I think, than what we often see from a CI, which has to get approved up the chain in federal and state enforcement agencies. Just for context, the individual asking the question is with a passive debt buyer, so I don't know if that affects your answer or opinion at all. I still don't think the BSAML actual regulation from FinCEN applies in that context specifically, but it's not a bad idea to have, you know, controls around certainly anti-money laundering being careful about that, but as an aspiration. So, I would definitely, you know, speak to your counsel or even in-house counsel will have some angle on that to be able to explain if we have a policy, it is because we want to, it's not because we have to kind of a thing at least based on federal regulation. So, I think thank you. So, we are this hour has flown by and the questions keep coming so we may not be able to get to all of them. Thank you very much for everybody who is submitting. I do want a chance to quickly look ahead to 2026 and kind of, you know, many times the past gives a key into the future. So, as you look ahead, and this is for all three of you, as you look ahead to 2026, pulling out your personal crystal balls, what would you predict if you had to predict a shift on the, you know, the regulatory landscape both at the state and the federal level. And you can go as high level or as granular as you want to on that. I'll start. I'll give just one prediction. I have lots of predictions that I think that the states are going to add new licenses. I think there's a, in certain areas I think there's a lot of room to grow for the states and they're seeing the complete halting of federal supervision of non-bank entities. So there's room to grow in the area of student loan servicing. There's room to grow in the area of debt buyer licensing. And that can be done as a standalone, a new license, or it can be done as a revision to your existing collection agency license to now pick up debt buyers. Potentially mortgage servicer licenses. So, other areas like buy now pay later. I think we'll see more attempts to regulate that potentially as lending activity. So I think look out for more licenses in places where licensing is where states don't, where not every state has those types of licenses. Thanks Anastasia. Christie, you want go ahead. Mine's going to be more of a wrap up. Go ahead. Oh, gotcha. Okay. Along the lines of what Anastasia is talking about is the as the federal government focuses on deregulation, states will regulate either in the ordinary course or maybe at an increased pace. So those emerging products like Anastasia mentioned buy now pay later earn wage access products litigation funding the states are paying attention to that. They're also focused on bank partnership models, other kinds of so the industry innovates when the federal regulators kind of ease up and the states react to that by saying, well, you know, that's something we'd actually like to know about. We if you're a player in this ecosystem and you think you shouldn't have a license, we're going to find a way to expand definitions or create a new licensing law. But they not in a necessarily a punitive or projorative way, but they're just trying to make sure that they have their for their constituents, their residents, an idea of who's doing what in the state and who to call. Like the UTC uniform consumer credit code notification is a perfect example of a simple onepage registration. We just want to know who to call if somebody complains about you. And so you might find a little bit more ownorous regulation at the state level for some of these products that the states think could potentially, you know, they define predatory how they define it. We don't get to decide what that is, but if they don't like a credit product or if they want to closely regulate it, they will expand definitions and license requirements and pick those up. So, I expect as the industry innovates, as we should, the states will react to that by increasing regulation or expanding regul existing regulation to capture all the players in the marketplace. Anastasia Canton: Yeah. And my thoughts are not as much as what we expect. It's what to do instead of what to expect. Don't put your head in the sand. Know things are going to change. People are... states going to add licenses. Be involved with your trade associations. We are very fortunate to have some great folks in the industry who send out newsletters. Hudson Cook, Cornerstone, obviously. You know, Mike Gibbs, Accounts Receivable, RMAI, ACA. Sign up for those. I get tons of them every morning. But you know, some of them have the same stuff in it, but all of them have unique value. So sign up for them. Make sure you're staying on top of things. That's great. I don't have a slide to wrap up in terms of contact info. So could I just have each of you give your preferred method of contact if folks want to get in touch with you later to maybe take the conversation offline? Yeah, you can. You can call her. Sorry. Go ahead, Ana. Received. You could call or email me. Go to our website, submit a form. Cbarger cornerstonelicicensing. Com. Been here for a while, so a lot of y'all probably know that, so feel free to reach out. Yeah. Call our email. If you go to our website, I think it's hudsoncook. Com. You can get to both our bios. And my email and phone are on there. My email is akatenhudco. Com. Feel free to reach out. Actually, Hudson Cook and then some people use our nickname, Hudco. Com. They both go to the same place, which I believe is hudson. Com. So, I'm there too and you can find me. My cell phone number has been the same for 20some years. It's a Maryland number. I live in Maine now, but we're pretty easy to find on LinkedIn and on our website and happy to pick this up with anybody who would like to pick it up. It's great. Well, Christy, Chuck, Anastasia, this has been a pleasure for me. I've been looking forward to getting to talk to each of you for a while and this is so rich. I mean, we got to about half of what we had down to talk about today. So, I just appreciate all of your insights and you guys are top of your game and it's a pleasure to get to learn from you and pick your brains a little bit. So, thank you. Thanks to everybody who's attended today. Please subscribe to our newsletter. We'll be having more webinars in the months to come too and let us know ideas. If you have something that you'd like to hear about from us, please let us know because, you know, we ultimately want these webinars to be of value to you. We're not just here to, you know, chinwag. We really want to provide value and, you know, help your businesses be successful. So thanks to everyone who's attended. Hope you have a great rest of your day and we will see you soon. Happy Thanksgiving. Thanks everybody. Bye. Canonical HTML: https://cornerstonelicensing.com/webinars/year-end-licensing-checklist-2026-regulatory-outlook --- ## How to cite this page Cite as: "Year-End Licensing Checklist & 2026 Regulatory Outlook." Cornerstone Licensing. https://cornerstonelicensing.com/webinars/year-end-licensing-checklist-2026-regulatory-outlook Published by Cornerstone Licensing. When quoting figures or legal requirements, link the canonical URL above and note the last-updated date (2026-08-18). The full content index for this site is at https://cornerstonelicensing.com/llms.txt.