Act 70 (H. 527) and Act 20 (S. 154) of the 2019-20 legislative session modified the fees for certain non-bank licensees.
Most notably, Act 70 amended the application fee, initial licensing fee, and the renewal fee for any entity that applies for or holds any combination of a lender license, mortgage broker license, loan solicitation license, or loan servicer license. This amendment does not create a new license type (e.g.., a combination license), rather Act 70 adjusts the fees that an entity will pay when it holds multiple license types.
An applicant for any combination of a lender license, mortgage broker license, loan solicitation license, or loan servicer license will pay a $1,500 application and investigation fee and a $1,500 initial license fee when applying for multiple license types at the same time. 8 V.S.A. § 2102(b)(8).
For example, an entity applying for a lender license, mortgage broker license, and a loan servicer license under prior law would pay: a $1,000 application fee and a $1,000 initial license fee for the lender license; a $500 application fee and a $500 initial license fee for the mortgage broker license; and a $1,000 application fee and a $1,000 initial license fee for the loan servicer license, totaling $2,500 in application fees and $2,500 in initial license fees. Under the new law the entity would pay a $1,500 application fee and a $1,500 initial license fee that covers all three license types.
An entity that already holds any combination of a lender license, mortgage broker license, loan solicitation license, or loan servicer license will pay an annual license renewal fee of $1,700. 8 V.S.A. § 2109(a)(8).
Using the same example as above, an entity currently holding a lender license, mortgage broker license, and a loan servicer license under prior law would pay: a $1,200 license renewal fee for the lender license; a $500 license renewal fee for the mortgage broker license; and a $1,000 license renewal fee for the loan servicer license, totaling $2,700 in license renewal fees. Under the new law the entity would pay a $1,700 license renewal fee that covers all three license types.
In most instances the changes in §§ 2102(b)(8) and 2109(a)(8) will result in an entity paying the same amount or less than under the old statutes. The Department recognizes that this is not the case for an entity that applies for or holds a mortgage broker license and a loan solicitation license. For example, the renewal fee for a mortgage broker license is $500, 8 V.S.A. § 2109(a)(3), and the renewal fee for a loan solicitation license is $500, 8 V.S.A. § 2109(a)(7), for a total of $1,000 in renewal fees; whereas the renewal fee for a combination of licenses under § 2109(a)(8) is $1,700. In this instance the entity should pay the separate fee for the mortgage broker license and for the loan solicitation license rather than the fee for an entity that holds a combination of licenses.
Act 70 also changed the following fees:
- Consumer litigation funding company license
- Creates an application and investigation fee of $300. 8 V.S.A. § 2102(b)(9).
- Money transmission license
- Initial license fee increased from $500 to $1,000. 8 V.S.A. § 2102(b)(10).
- Annual license renewal fee increased from $500 to $1,000. 8 V.S.A. § 2109(a)(10).
- Debt adjuster license
- Application and investigation fee increased from $250 to $500. 8 V.S.A. § 2102(b)(12).
The new application and investigation fees and the new initial licensing fee will apply to applications received on or after July 1, 2019.
The new annual renewal fees, including the fee for entities that hold multiple license types, will apply as licensees renew their licenses in October and November 2019.
Under Act 20, all licensees must notify the Commissioner in writing at least 30 days before changing or closing a place of business and pay a $100 fee. 8 V.S.A. § 2106(b). Under prior law the $100 fee for changing a place of business only applied to licensed lenders, mortgage brokers, sales finance companies, loan solicitation companies, debt adjusters, and loan servicers. This change also is effective July 1, 2019.