Licensing Insights: State Updates + CFES Spotlight

State Updates

‍Texas Transitions the Regulated Lender License onto NMLS
Effective July 15, 2025, the Texas OCCC has transitioned its Regulated Lender License from the Texas-specific ALECS portal and onto NMLS. All new company and branch applications for a Texas Regulated Lender License must now be submitted through the NMLS.

For existing licensees, the OCCC has opened up a transition period, which will run through September 15, 2025. Please note that this transition is mandatory. Licensees without existing NMLS accounts must first have one created. The NMLS Company Account Request Form can be found here and please see the FAQ for further guidance with that process. The OCCC has also made available a transition checklist, detailing all items that will be to be uploaded into NMLS to successfully transition away from the ALECS portal.

Further information regarding this change can be found on the OCCC’s website.

Georgia Eliminates Annual Report for Money Transmitters

The Georgia Department of Banking and Finance (GA-DBF) has confirmed the discontinuation of the Average Daily Balance of Outstandings Report, previously due 8/15 annually, for all Georgia Money Transmitter Licensees.

According to an email confirmation from Fernando Ornelas, Supervisory Manager at GA-DBF, the data previously captured by this report is now collected through the latest version of the NMLS Money Services Businesses (MSB) Call Report.

For more information or help evaluating how these changes may affect your licensing requirements, please contact FS Vector.

Delaware Waives Supervisory Assessment Fees

The Delaware Office of the State Bank Commissioner has confirmed it will not invoice supervisory assessment fees for the fiscal year ending June 30, 2026 (invoiced in July/August 2025). The change follows the enactment of House Bill 225, which temporarily suspends the minimum assessment requirements under 5 Del. C. § 105(e) and § 127(b).

The agency notified licensees of the waiver in a formal notice sent on July 3, 2025. The waiver applies to all licensees.

Questions may be directed to the Commissioner’s Office at (302) 739-4235.

New Arizona Collection Agency Report Due September 1, 2025

The Arizona Department of Insurance and Financial Institutions (DIFI) has introduced a new annual reporting requirement for licensed collection agencies: the Report of Annual Income (Form L-CAR). The report is used to determine the required surety bond amount under ARS § 32-1021(B), based on gross annual income from all business transacted in Arizona during the preceding year.

Bond Amounts Based on Gross Annual Income:

• Up to $250,000: $10,000 bond
• $250,001–$500,000: $15,000 bond
• $500,001–$750,000: $25,000 bond
• Over $750,000: $35,000 bond

“Business transacted in Arizona” includes:

• Debts collected from Arizona residents, regardless of agency location
• Collections made from Arizona offices, regardless of debtor location
• Collections on behalf of Arizona-based creditors

Key Deadline:

Form L-CAR must be submitted to FELicensing@difi.az.gov by September 1 each year. Failure to submit will render the license ineligible for renewal.

Collection agencies should review their Arizona income annually and ensure Form L-CAR is completed accurately and submitted on time. For guidance or support, please contact FS Vector.

Service Spotlight: Coalition for Financial Ecosystem Standards (CFES)

Bank-fintech partnerships drive innovation, yet fragmented compliance frameworks create operational barriers and regulatory uncertainty. FS Vector incubated the Coalition for Financial Ecosystem Standards (CFES) to address this challenge by creating industry-leading standards and certification for nonbank financial service providers.

The Standardized Assessment for Risk Management and Compliance (STARC) framework covers 54 core standards across critical areas, including BSA/AML, Compliance Management Systems, Third-Party Risk Management, Complaint Handling, Operational Risk, and Marketing Compliance. The STARC certification process offers a structured approach for fintechs and partner banks to demonstrate sound compliance practices while streamlining due diligence processes that traditionally cost banks millions annually. CFES is currently developing lending standards that address areas such as model risk management, loan origination and underwriting, consumer lending compliance, and commercial lending requirements.

Nonbanks and fintechs can engage with CFES in two key ways: join as members to shape the future of bank-fintech partnerships by providing direct input on standards development and leading technical working groups, or pursue certification to demonstrate compliance maturity appropriate to their business model, risk profile, and growth stage. CFES understands that innovative companies have unique needs. The flexible rating system allows organizations to demonstrate compliance excellence, whether they're startups building foundational programs or established entities refining advanced strategies. Visit the website to learn more or reach out to info@thecfes.com.

FS Vector Calendar

Events FS Vector Licensing Team is attending

• American Association of Residential Mortgage Regulators | August 5-7 | Fort Worth, TX
  • RSVP Link Join us during AARMR’s 35th Annual Conference for a reception at Tannahill’s!
• MTRA  | Sep 8-11 | Louisville, KY
• Money20/20 | Oct 26-29 | Las Vegas, NV
• RegList on the Ocean | Nov 4-5 | Huntington Beach, CA