Regulatory AlertsUS Federal: lending & credit regulation
RegulatedUS lending: State-by-state licensing; federal consumer protection via CFPB and FTC
- Lead regulator
- CFPB (consumer) · FTC (unfair practices) · State regulators (licensing)
- Core law
- Truth in Lending Act (TILA) · Dodd-Frank Act · State Consumer Credit Codes
- Entry capital
- None (federal); varies by state (e.g., $50k-$500k)
- Approval timeline
- 3-12 months per state (varies)
- Customer assets
- No federal escrow mandate; state rules vary
- Data protection
- GLBA · FTC Safeguards Rule · State laws (e.g., CCPA)
- Sandbox
- No
Lending in the US is primarily regulated at the state level, requiring licenses in each jurisdiction where borrowers reside. Federal agencies like the CFPB and FTC enforce consumer protection and fair lending laws. There is no single federal lending license for non-bank originators.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Consumer lending | LicenceState Consumer Finance License[1][2] Required in most states for non-bank lending | Varies by state | 3-12 months | State Banking/Financial Regulators |
| SME / commercial lending | LicenceState Commercial Lending License Often requires separate licensing from consumer | Varies by state | 3-12 months | State Banking/Financial Regulators |
| Microfinance | LicenceState Consumer Finance License Subject to same state licensing as consumer lending | Varies by state | 3-12 months | State Banking/Financial Regulators |
| Buy-now-pay-later | LicenceState Consumer Finance License Increasingly regulated as consumer credit | Varies by state | 3-12 months | State Banking/Financial Regulators |
| P2P lending platform | LicenceState Consumer Finance License Platform must be licensed in borrower states | Varies by state | 3-12 months | State Banking/Financial Regulators |
| Credit bureau / scoring | RegistrationFCRA Compliance Must comply with FCRA for consumer reports | — | — | CFPB · FTC |
| Debt collection | LicenceState Debt Collection License Required in many states for third-party collectors | Varies by state | 1-6 months | State Banking/Financial Regulators |
New — what changed recently
- 2025-12-15Regulation Z Threshold Adjustment — CFPB and Fed adjusted TILA exemption thresholds for consumer credit based on CPI.[3]
- 2025-12-16Higher-Priced Mortgage Loan Appraisal Threshold — OCC, Fed, and CFPB updated the exemption threshold for appraisals on higher-priced mortgage loans.[4]
- 2025-07-30FDIC Consumer Compliance Examination Manual Update — FDIC updated guidance on fair lending compliance under ECOA and Fair Housing Act.[5]
- 2024-08-07AVM Quality Control Standards — Interagency final rule on quality control standards for automated valuation models.[6]
Market-entry checklist
- 1Identify state licensing requirementsDetermine which states require licenses for your lending activities.
- 2Apply for state licensesSubmit applications to each state's banking or financial regulator.
- 3Ensure TILA/RESPA complianceImplement systems for accurate disclosure of loan terms and costs.
- 4Register as FCRA compliant entityEnsure credit scoring and reporting practices meet FCRA standards.
- 5Establish fair lending policiesCreate and document policies to prevent discrimination in lending.
- 6Secure data protection measuresImplement GLBA and FTC Safeguards Rule compliance for data security.
Sources
- Bulletin 2025-2: Oregon Consumer Finance Licensing Requirements · 2025-02-19
- 2025 Kansas Consumer and Mortgage Lending Law Book Guidance
- Truth in Lending (Regulation Z) 2026 Threshold Adjustment · 2025-12-15
- Appraisals for Higher-Priced Mortgage Loans Exemption Threshold · 2025-12-16
- Update to the FDIC’s Consumer Compliance Examination Manual · 2025-08-29
- Quality Control Standards for Automated Valuation Models · 2024-08-07
This guide is compiled automatically from 6 primary-source documents published by US Federal's regulators, reviewed by RegAlert, and refreshed monthly (last updated 2026-07-12). It is not legal advice — always confirm requirements with the regulator or local counsel before acting.