December 19, 2023



Welcome to Licensing Link, a periodic publication that will keep you informed on hot topics and new developments in state licensing laws, and provide practice tips and primers on important issues related to state licensing across the spectrum of asset classes and financial services activities. We look forward to you joining us for future editions!

Licensing link

Florida Becomes Latest State to Introduce “True Lender” Legislation

Florida Becomes Latest State to Introduce “True Lender” Legislation - Florida's Senate Bill 146, introduced for the 2024 session, follows the "true lender" trend seen in other states. The proposed legislation aims to prevent predatory lending practices by amending the Florida Consumer Finance Act, establishing anti-evasion measures and re-characterizing certain nonbanks as lenders. If enacted, the law would take effect on July 1, 2024, and would render loans originated in violation of the anti-evasion provision void and unenforceable. Read More>>


Wisconsin Clarifies No-Fee Advances Are Not “Payday Loans”

Wisconsin clarified on November 16, 2023, that advances of money where the lender does not require or accept any fees or charges are not considered "payday loans." The amendment enables fee-free lenders in the state to operate without a payday lender license, including those facilitating electronic fund transfers, as outlined in Senate Bill 259, effective from November 18, 2023. Read More>>


For more information about this topic, please contact the editors, Krista Cooley, Partner, Washington DC at and +1 202 263 3315 and Frank Doorley, Partner, Washington DC at and +1 202 263 3409.

For more than 20 years, our Financial Services Regulatory and Enforcement practice’s licensing team has helped clients engaged in lending and other consumer credit activities navigate every aspect of state licensing. We routinely undertake nationwide licensing and renewal efforts involving all manner of professional licenses for consumer credit-related activities, including mortgage lending, brokering or servicing, consumer lending and brokering, commercial mortgage and non-real estate-secured commercial or business activities, collections, money services or money transmitter businesses, sales finance activities, and real estate broker activities. We not only help companies evaluate the need for and obtain state licenses but also help steer them through license renewals, examinations and required reporting, changes of control, and license surrenders and provide other services that help companies remain in good standing with state licensing regulators.

Legal Update
Legal Update
Legal Update

Chambers Fintech 2024

 Ranked Band 1 in FinTech: Payments & Lending (US) and in FinTech: Corporate, Securities & Financing (US); also ranked in FinTech: Legal (US) and FinTech: Data Protection & Cyber Security (US).

Chambers USA 2023

Ranked Band 1 in: Financial Services Regulation Consumer Finance (Compliance)—also ranked in: Financial Services Regulation: Consumer Finance (Enforcement & Investigations) and Consumer Finance (Litigation).


8 Practice Groups of the Year in 2022, including Banking, Class Action, and Cybersecurity and Privacy; Firm of the Year 2016-2020.