MA Amends Truth in Lending, Mortgage Lender and Broker Licensing, and Small Loan Regulations

The Massachusetts Division of Banks (DOB) amended several regulations. In its Truth in Lending regulations, the DOB changed the timing for depository institutions to disclose the first payment change notice to borrowers with variable rate mortgage loans to at least 60 but no earlier than 120 days before the first payment change is due.

The DOB clarified that a mortgage lender or broker licensee must provide their NMLS ID to mortgage loan applicants, in writing, at the time a fee is paid, or at the time the application is provided to the applicant, or at the time the application is presented to the applicant for signature.  The amendment does not clarify whether the NMLS ID must be provided at the earliest of these events.

Finally, the Small Loan Law regulations were amended to, among other things, broaden the kinds of financial documentation the DOB may require when evaluating evidence of an applicant’s financial responsibility to obtain a license.  The amendments also include additional notifications for certain events and an annual report filing requirement.

The amendments became effective on October 10, 2025.