January 30, 2023

Volume XIII, Number 30

Advertisement

January 30, 2023

Subscribe to Latest Legal News and Analysis
Advertisement

Washington, D.C. Publishes Bulletin Reminding Student Loan Servicers of Annual Report

The Washington, D.C. Department of Insurance, Securities, and Banking (DISB) has published a Bulletin reminding those who service student education loans in the District of Columbia of their obligation to file an annual report.

Section 3014 of the DISB’s regulations, finalized August 10, 2018, requires that a licensee submit an annual report, on or before January 30 and in a form prescribed by the Commissioner, describing the number of student loans sold, assigned, or transferred during the preceding calendar year and any other information required by the Commissioner. The Bulletin does not state that the annual report form has been finalized, although it is anticipated that the DISB will release the report in the next month. The Bulletin also does not state whether the DISB will require an annual report for calendar year 2018 and, if so, when licensees must file such a report. Failure to file a timely report is subject to a late penalty of up to fifty dollars per day.

Because the federal district court for the District of Columbia found provisions of the District’s student loan servicing law to be preempted by the Higher Education Act in Student Loan Servicing Alliance v. District of Columbia, et al., the Bulletin clarifies that “a licensee is only required to provide information on the licensee’s non-federally owned loans.”

Copyright © by Ballard Spahr LLPNational Law Review, Volume IX, Number 134
Advertisement
Advertisement
Advertisement

About this Author

Brian Slagle, Philadelphia lawyer, Ballard Spahr law firm
Associate

Brian J. Slagle is an associate in the Business and Finance Department and a member of the Consumer Financial Services Group. His practice focuses on providing regulatory advice to clients on state and federal consumer finance laws. He regularly assists clients with a range of compliance and transactional issues relating to licensing, the Truth in Lending Act (TILA), Equal Credit Opportunity Act (ECOA), Electronic Funds Transfer Act (EFTA), Electronic Signatures in Global and National Commerce Act (ESIGN), the Telephone Consumer Protection Act (TCPA), the Fair Credit...

215-864-8472
Culhane, Ballard, Partner
Partner

John L. Culhane, Jr., is known for his work advising on interstate direct and indirect consumer and residential mortgage loan and leasing programs, through both traditional brick-and-mortar facilities and e-commerce. Before joining Ballard Spahr, Mr. Culhane was associate counsel with Mellon Bank, N.A.; associate counsel with Bank of America NT&SA; and senior attorney (section chief) with the National Credit Union Administration, the federal agency regulating federal credit unions.

Mr. Culhane addresses issues involving licensing,...

215-864-8535
Advertisement
Advertisement
Advertisement