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Opinion Summary of Selected Opinion 97-247

Date: 10/08/1997
Organization: Division of Banks
Docket Number: 97-247

This opinion was issued during the fourth quarter of 1997.

Table of Contents

License Requirements For "Loan Processing Centers"

A licensed Small Loan Agency may restructure its production network in such a way that loan solicitation will occur at existing branch offices and loan processing, underwriting, and preparing closing documents, with some customer contact, will occur at the processing centers. It is the position of the Division of Banks that separate small loan agency licenses would not be required for such processing centers. This position is based on the assumption that loan solicitation activities would not take place at the processing centers, that such centers would not be generally accessible to the public and they will not create an impression to the public that loans are being made and/or solicited from these locations. However, if a loan processing center does not meet the requirements listed above, it may be considered a branch and subject to licensing requirements within the Commonwealth.