September 14, 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

No Recourse, No License? Not Quite.

In the July edition of Licensing Link, we addressed licensing developments for novel earned wage access products designed to allow employees access to their earned but unpaid wages on a non-recourse basis. In this article, we discuss the application of state licensing laws and recent licensing developments related to other innovative non-recourse financial products: income share agreements (“ISAs”) and home equity option agreements. Read More>>


A Quick Update On Work-From-Home Requirements for Oregon MLOs

In the May edition of Licensing Link, we discussed the growing trend of states issuing guidance or amending their licensing laws to permit mortgage loan originators and consumer lenders to engage in remote work since the onset of the COVID-19 pandemic. In October 2022, the Oregon Department of Financial Regulation issued regulations under its Mortgage Lending Act that we have summarized. 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 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.

Chambers Fintech 2023

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