Compliance Alerts

September 2021


Effective State Changes



On August 25, 2021, the emergency filing of the Colorado Student Loan Servicers Act Rules—4 CCR 902-3—were adopted. Effective September 1, 2021.



On August 27, 2021, Governor JB Pritzker signed House Bill 2746 the Know Before You Owe Private Education Loan Act into law. The new law affects private education lenders and has a number of requirements to provide information to students before they enter these loans. Additionally, the law requires these lenders to file reports with the Department of Financial and Professional Regulation. Effective immediately.


Governor John Sununu approved of House Bill 610 on August 10, 2021. Among other provisions, the new law requires retail sellers, sale finance companies, small loan lenders, debt adjusters, and money transmitters to license via the Nationwide Multistate Licensing System and Registry in New Hampshire. Effective October 9, 2021.



House Bill 403 was signed into law by Governor Roy Cooper on September 10, 2021. The new law makes several changes to North Carolina's Motor Vehicle Dealers and Manufacturers Licensing Law. Among other provisions, the bill prohibits conditioning approval of dealership transfers on a dealer's willingness to renovate, relocate, or other conditions. Additionally, among other provisions the new law:

  • Extends conditions for certain manufacturer incentive programs.

  • Clarifies changes to existing law regarding warranties.
  • Ensures delivery of prepared documents at a customer's home will not violate salesroom restrictions for vehicle sales.

Effective immediately.


Governor Cooper also enacted House Bill 650 on September 2, 2021. This new law makes a number of changes to the existing motor vehicle and motor vehicle dealer laws. Changes include:

  • Clarifies sales representative licensing provisions.
  • Modifies the grounds for revoking sales representative licenses.
  • Limits the ability to revoke the licenses of vehicle dealers.

Effective October 1, 2021.


Senate Bill 379 requires the North Carolina DMV to issue an unregisterable certificate of title for motor vehicles. In addition, it establishes an application process to apply for an unregistrable certificate of title. Effective October 1, 2021.





Section 3-508A increases the cap on loan finance charges from 27% to 32% per year on unpaid balances of the principal of $7,000 or less, 23% per year on the unpaid balances of the principal more than $7,000 to $11,000, and 20% on the unpaid balances of the principal more than $11,000. The bill also provides for a closing fee upon prepayment in full of up to $28.85 under Section 3-210. Effective November 1, 2021.


Effective Federal Changes     



On August 31, 2021, the Consumer Financial Protection Bureau (“CFPB”) released a notice for proposed rulemaking in order to collect and report on credit applications made by small businesses. The focused collection will analyze data from minority and woman owned businesses. Comments will be accepted until November 29, 2021.