WBK Industry News - State Regulatory Developments

Vermont Creates New Combination License Available to Certain Licensees

The Vermont Department of Financial Regulation created a new type of license—a Combination License—which combines the lender license, mortgage broker license, loan solicitation license, and loan servicer license in the state.  To be eligible for the Combination License, each applicants’ business must be covered by two or more of these four license types.

The Combination License is available for both companies and branches, whether or not located in Vermont, engaging in the business activities covered by the license.  The related license requirements include, among other things: licensure to engage in the combination business activities in the applicant’s state of domicile (or evidence of exemption from such licensing or registration requirements); good standing in the applicant’s state of domicile with its banking regulator or equivalent financial industry regulator; generally no prior revocation of a lender license, mortgage broker license, mortgage loan originator license, or similar license of the applicant (or each officer, director, and control person of the applicant); certain application fees; a minimum bond beginning at $200,000; and a registered agent recorded with the Vermont Secretary of State.

Additionally, for a limited time, companies currently holding two or more of the four license types have the option to transition both company licenses and branch licenses (for any branch location holding more than a single applicable license type in the state) to the Combination License.  License transition requests must be submitted through the NMLS between March 1, 2020, and May 15, 2020, including related NMLS transition/processing fees.

The recently released NMLS checklists for the company and branch Vermont Combination Licenses, as well as checklists for the related transition requests, can be found here.