Effective July 1, 2020, the Vermont legislature amended the law governing lender licensees, loan servicer licensees, and sales finance licensees to remove the requirement that license applicants provide proof that they are licensed to engage in the applicable business in their home state. With this development, the already short list of state financial services regulators enforcing such a requirement became significantly shorter.
Previously, license applicants whose activities did not trigger licensure in their home state had to request a waiver of the requirement from the Vermont Department of Financial Regulation and then enter into a memorandum of understanding (MOU) with the department. The MOU represented that in the event that the company’s business changed to include an activity that triggered licensure in their home state, then the company must apply for a license from their home state within 60 days. The department also required that a copy of the MOU be uploaded to the company’s Form MU1.
With one less requirement to address, certain Vermont license applicants should find the application process slightly less burdensome. As of the date of this post, the department has not updated the applicable New Application Checklists on NMLS to reflect this change.