Compliance Alerts

July and August 2021


Effective State Changes



Senate Bill 076 imposes a per-transaction fee up to $3, set by the Department of Revenue, on third-party providers to issue titles, registrations, and liens. Effective July 7, 2021.



Senate Bill 716 provides additional protections for student loan borrowers and cosigners of private education loans. The bill also presents a new cause of action which can be brought against student loan servicers who engage in abusive acts or practices. Effective July 1, 2021.

Governor Ned Lamont signed Senate Bill 890 requiring federal student loan servicers to register with the Connecticut Department of Banking and comply with record requirements and consumer protection mandates applicable in the state. Effective July 1, 2021.



The Motor Vehicle Franchise Act has been amended by House Bill 3940. The new law requires licensed dealers to sell all motor vehicles instead of stating unlicensed dealers should be prevented from these sales. Additionally, this bill alters the manner in which dealers are reimbursed by manufacturers among other changes. Effective January 1, 2022.

Senate Bill 58 restores the full sales tax trade-in credit on vehicle trade-ins. Two years ago, lawmakers capped the sales tax trade-in credit at $10,000 for some passenger vehicles and SUVs. Restoring the full credit will give all motor vehicle customers a tax credit equal to the full value of their vehicles. Effective January 1, 2022.

The Debt Settlement Consumer Protection Act now includes student loan borrowers following the passage of Senate Bill 669. Among other requirements, the bill provides for specified disclosures in advertising and in contracts before signing. Effective Immediately.



Governor Janet Mills signed Legislative Document 522 granting to Maine consumer's the right to void a loan that is fraudulently procured under Maine finance law. The role of this new law is to crackdown on predatory lending in Connecticut. Effective 90 days after adjournment.

Legislative Document 1645 is an act that creates a registry of student loan lenders and implements other protections for private student loan borrowers. Effective 90 days after adjournment.



Oregon declared a student loan emergency and enacted Senate Bill 485 in response. The law requires certain student loan servicers to obtain or renew license in Oregon. In addition, the bill details application and renewal procedures, required fees and creates certain exemptions. Finally, the new law allows for civil penalties against an unlicensed servicer and permits the Director of the Department of Consumer and Business Services to participate in multistate examinations. Effective July 1, 2022.



On August 10, 2021, the Order Adopting Adjusted Prima Facie Rates for the Triennium Commencing January 1, 2022, Case No. INS-2021-00023 was announced. The Virginia State Corporation Commission's has enacted new rates for a 3-year period The new rates will be:

Credit Life Rates


Single Life Rate                      $0.6672/$1000/month

Discounted at 3.63% for interest and mortality

Joint Life Rate                        $1.1008/$1000/month

165% of single life rate


Single life rate per $100 @ 12 months         $0.4259 

Joint life rate per $100 @ 12 months           $0.7027


Single Level Life per $100 @ 12 months     $0.7792

Joint Level Life per $100 @ 12 months       $1.2856


*Level life rates are derived from the rates per $1000 per month and discounted at 5.5% for interest and mortality.


Credit A&H Rates


14 Day Retro                             $1.56/$100 @ 12 months

30 Day Retro                            $1.12/$100 @ 12 months 

14 Day Elim                               $1.25/$100 @ 12 months 

30 Day Elim                              $ 0.78/$100 @ 12 months


This most recent change is a decrease in prima A&H facie rates.


Effective January 1, 2022.