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Recent legal opinions of the Division of Banks

Through these opinions the Division of Banks (DOB) offers perspective on current issues and questions in the financial services industry.

2017 Selected Opinions

  • Selected Opinion 17-003
    • Small loan licensing requirement for licensed motor vehicle sales finance company financing “negative equity” as part of motor vehicle sales finance contract – January 8, 2018
  • Selected Opinion 17-009
    • Licensing requirement for an entity operating a mobile application that facilitates payments between homeowners and home improvement contractors – December 19, 2017
  • Selected Opinion 17-005
    • Does acquiring a mortgage as a result of a defective foreclosure require a debt collector license – October 24, 2017
  • Selected Opinion 17-007
    • Does the business of selling and buying bitcoin through kiosks require licensure by the Division – October 24, 2017
  • Selected Opinion 17-008
    • Can a service fee be charged by third party payment processor for payments by credit card for insurance premium payments – October 24, 2017
  • Selected Opinion 17-001
    • The use of professional employer organization services - May 10, 2017


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