Regulatory Alerts2011-04-22 | ISGC-2011-002-DFIWithdrawal of Agency Interpretation Regarding State Bank Residential Mortgage Operating Subsidiary Subject to Consumer Loan Act
The Washington State Department of Financial Institutions withdraws its 2008 agency interpretation that exempted state bank subsidiaries from state licensing. This change takes effect on July 21, 2011, when the Dodd-Frank Act amendments empower states to regulate non-depositary subsidiaries of national banks and federal thrifts. Consequently, these subsidiaries must now obtain licenses under the Washington Consumer Loan Act, although their mortgage loan officers remain exempt from individual licensing requirements.
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