Per an update from ACA International, the state of Connecticut’s Department of Banking has issued a memorandum regarding a new law that is set to go into effect on Oct. 1, which requires all companies that have a license to conduct business in the state to conduct their business from inside a U.S. state.
However, since many companies that obtained licenses did so prior to the law being enacted, the Department of Banking will not take any action until after Dec. 31, 2018, as long as the company has a valid license to operate in Connecticut.
Collection agencies are one of the groups of financial services companies that are subject to the new law.
Under the new law, any activity that is subject to obtaining a license “shall be conducted from an office located in a state.” But the Banking Department is taking into consideration the fact that many companies that obtained licenses did so before the law went into effect, and complying with the new law could be problematic.
“The Department recognizes that Connecticut licenses for offices not located in a ‘state’ have already been issued and, by their terms, are effective through December 31, 2018. Accordingly, pursuant to Section 36a-1-8 of the Regulation of Connecticut State Agencies, this Department takes a no-action position concerning the requirement that any Connecticut activity by the above-referenced licensees be conducted from within a ‘state’, as defined by Section 36a-2, for the period of October 1, 2018 to December 31, 2018, when the following condition is present:
The entity or individual engaging in business is deemed to have an otherwise valid license for such activity, effective through December 31, 2018, to conduct said business under the controlling statutes prior to the requirement that the licensed activities be conducted from an office located in a ‘state’, as defined in Section 36a-2(64) of the Connecticut General Statutes.
