Connecticut Banking Dept. Issues Cease and Desist Order to Stop Fintech Loan Finder From Operating Without Small Loan License

Stacey L. Valerio focuses her practice on the mortgage banking industry. Stacey has more than 20 years' experience, including nearly a decade at the State of Connecticut Department of Banking's Consumer Credit Division, where she handled licensing and enforcement matters, with primary focus on the mortgage industry. In that role, she counseled the Consumer Credit Division, served as an administrative hearing officer, and drafted legislation, legal opinions, and rulings. The position also involved working with various other state and federal agencies, including the state Office of the Attorney General, the FBI, and the CFPB. Stacey was active with the State Regulatory Registry LLC's Lawyers Committee for many years, serving as its chair from 2014 to 2017, and was actively involved with the American Association of Residential Mortgage Regulators (AARMR), serving as a director and an officer. Stacey has experience counseling clients on a wide variety of regulatory matters at the federal and state levels. Her experience includes licensing and regulatory compliance, legislative initiatives, contract drafting, and the Nationwide Multistate Licensing System & Registry (NMLS). Stacey presently co-Chairs the Connecticut Mortgage Bankers Association, Inc.’s (CMBA’s) Closing and Compliance Committee.

Lisa Lanham’s practice focuses on financial services matters related to the state licenses and federal approvals necessary to conduct business for a variety of asset classes and market participants. Her clients include, but are not limited to, residential and commercial mortgage brokers, lenders, servicers, and loan fulfilment providers; student, consumer, and solar loan lenders and servicers; entities offering retail installment contracts for the purchase of consumer goods; marketplace lenders; and investors who engage in secondary market activities related to these business lines. She also works with early-stage Fintech companies in all of these business lines to help develop products mindful of state licensing and regulatory compliance requirements and obtain and maintain any required state licenses and approvals necessary to engage in business. Lisa has robust experience and positive working relationships with key regulators, including the New York State Department of Financial Services, and leverages them to usher her clients through the process of obtaining and maintaining any required licenses and approvals, completing audits and examinations, explaining difficult disclosure issues, and reporting changes of ownership, executive management, and qualifying individuals. Lisa was involved in the development of the Nationwide Multistate Licensing System & Registry (NMLS) 2.0 system. She is proficient at all facets of the NMLS, including submissions and amendments of company and branch application forms and electronic surety bonds, transitions and renewals of state licenses, submissions of mortgage call reports and money services business call reports, and coordination of larger transactions affecting multiple state licenses.

Michael Guerrero has more than a decade of experience advising companies across a wide range of industries on consumer protection and consumer financial services issues, including clients offering point-of-sale and personal property financing and leasing, rent-to-own products, and installment loans. He helps clients navigate compliance with state and federal calling and telemarketing, retail installment sales, lending, and payments laws. He regularly provides guidance on the structuring and documentation of consumer credit programs involving the financing of goods or services. He has advised banks, professional sports teams, Fintech companies, retailers, and automotive finance companies. Mike has worked with consumer financial services providers of all sizes, from startups and emerging companies to publicly traded companies, on matters involving all stages of the credit product lifecycle—from advertising and origination to repossession and disposition. Mike also assists clients with personal property financing and rental programs, as well as structuring both marketing and non-marketing telephone calling and texting campaigns. Mike has extensive experience counseling clients on matters relating to the Truth in Lending Act (TILA), the Fair Credit Reporting Act (FCRA), the Electronic Funds Transfer Act (EFTA), the Equal Credit Opportunity Act (ECOA), the Telephone Consumer Protection Act (TCPA), prohibitions on unfair, deceptive or abusive acts and practices (UDAAP), UCC Art. 9, Federal Trade Commission rules and guidelines (e.g., the Holder Rule, Cooling Off Rule, Telemarketing Sales Rule, Credit Practices Rule, and advertising guidelines), retail installment sales, and home improvement financing. Before joining Ballard Spahr, Mike held in-house positions, including working for an e-commerce retail installment sales company, a mortgage lender, and a publicly traded debt buyer. While in-house, he oversaw legal and compliance efforts associated with the launch of a nationwide payroll deduction repayment-based retail installment sale product; obtained and renewed hundreds of debt collection, debt purchasing, retail installment, sales finance, and mortgage lending licenses; interacted with state regulators; and oversaw regulatory examinations.