Licensing
Licensing Insights: IL Educational Income Share Agreement, MCR State-Specific Supplemental Form, IN EWA License Now in NMLS, The DFPI Issues New Draft Regulators for DFAL, DC Dept of Insurance, Securities and Banking Adds License to NMLS Effective Oct. 1
October 8, 2025
Effective on August 15, 2025 - Illinois Expands Student Loan Servicer Law to Include EISA Providers
On August 15, 2025, Governor Pritzker signed into law Public Act 104-0383, which amends the Student Loan Servicing Rights Act to impose licensing, servicing, and other requirements on providers of Educational Income Share Agreements (EISAs). The Act took effect immediately upon becoming law. Read the full text of the Act here.
Licensing Impact
Under the law, providers of EISAs are expressly treated as “student loan servicers” and become subject to licensure and regulation by the Illinois Department of Financial and Professional Regulation. Companies offering or marketing EISAs in Illinois must now obtain and maintain a student loan servicer license. This requirement applies to both new applicants and existing EISA providers currently operating in the state.
Substantive Requirements
The Act establishes limits on repayment terms, fees, and disclosures for EISA products. It also clarifies that EISA providers are exempt from the Consumer Installment Loan Act only when operating within the scope of this framework.
The Illinois Attorney General may enforce violations of the new requirements as unlawful practices under the Consumer Fraud and Deceptive Business Practices Act.
FS Vector helps clients navigate the licensing and compliance requirements for student loan servicers and related financial services, including assistance with obtaining an Illinois Student Loan Servicer License. Contact us to learn more about how these changes may impact your licensing strategy.
MCR State-Specific Supplemental Form
FS Vector is encouraging all licensees to review the most recent revisions to the Mortgage Call Report (“MCR”) (MCR V6) and assess whether your company must update its reporting practices to capture and report applicable activity.
We have observed an increase in state regulators contacting licensees where the State-Specific Supplemental Form (“SSSF”) appears as a required submission- particularly in cases where licensees reported zero activity despite having reportable transactions.
As a reminder, effective Q1-2024, the MCR was updated to include the SSSF, enabling states to collect data on activities not otherwise captured in the standard MCR. Beginning April 1, 2024, all applicable licensees became subject to this requirement and were expected to report activity reflective of Q1-2024.
FS Vector again encourages all licensees to review these updates carefully and confirm whether additional reporting under the SSSF is required for your organization.
The Nationwide Multistate Licensing System (“NMLS”) has updated its License Requirements and Fees Chart to incorporate the state-specific guidance that may assist licensees in these efforts. Click HERE to access the chart. While not all states have issued formal positions, several have provided direction – including, for example, the state of Washington. Click HERE to view Washington’s announcement related to these changes. Information on the SSSF can also be found on state-specific checklists.
Contact us to learn more about how FS Vector can help with the MCR SSSF reporting efforts!
Indiana Earned Wage Access License Now in NMLS
The Indiana Earned Wage Access Act (EWAA) became law on May 6, 2025. As a result, licensure under the EWAA is required for Earned Wage Access (EWA) activities starting January 1, 2026. As of October 1, 2025, the application is now available through the Nationwide Multistate Licensing System (NMLS). Activities authorized by the EWA license are not covered under other Indiana licenses, such as the Small Loan license or Money Transmitter license. Entities currently holding one of these licenses must apply for a new EWA license to engage in EWA activities after December 31, 2025. It is highly recommended submitting applications in October 2025 to allow the agencysufficient time for review before January 1, 2026. Applications submitted after April 30, 2026, will be considered delinquent.
Contact us to learn more about how FS Vector can help with the EWA license acquisition.
The DFPI Issues New Draft Regulators for the Digital Financial Assets Law
On September 29, 2025, the California Department of Financial Protection and Innovation (“DFPI”) published new draft regulations related to licensure under the Digital Financial Assets Law (“DFAL”). The newly proposed regulations include clarifications to existing exemption language to better articulate that certain transactions, which will be subject to DFAL, are exempt from the California Money Transmission Act. The specified exempt activity includes money transmission conducted by DFAL licensees for the purpose of buying or selling digital financial assets, as well as stored value issued by DFAL licensees for the purpose of buying or selling digital financial assets. The proposed regulations also clarify that the definition of “control” is triggered by a 10% threshold, but that the finding of control creates a rebuttable presumption.
The comment period for the current draft of the regulations closes on October 15, 2025. The notice for the proposed regulations can be found here; the current draft of the proposed regulations can be found here; and a summary of the changes in the regulations can be found here. The DFAL itself is scheduled to go into effect on July 1,
2026.
District of Columbia Department of Insurance, Securities and Banking to Add New License to NMLS Effective Oct. 1
Starting on October 1, NMLS will receive new application filings for the District of Columbia Department of Insurance, Securities and Banking Department's new Automatic Student Loan Servicer License.
New applicants will be able to submit these records through NMLS starting on October 1, 2025.
FS Vector Calendar
Events FS Vector Licensing Team is attending
- Money20/20 | Oct 26-29 | Las Vegas, NV
- 2025 NACARA Conference - Oct 28-30 - Boise, ID
- RegList on the Ocean | Nov 4-5 | Huntington Beach, CA - Contact us for a discount code to attend!
- FinTech NerdCon - Nov 19-20 - Miami, FL
Upcoming FS Vector Webcasts
- FS Vector Licensing Lunch & Learn: Real Talk: Real Estate Licensing & More - November 5, 2025
FS Vector, and a guest from Rocket Home/Redfin, will discuss Real Estate licensing including reciprocity. They will also discuss common license violations to be aware of how to prepare to mitigate any potential problems.