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Washington, D.C. Releases Annual Report Forms and Filing Deadlines

As recently reported, the Washington, D.C. Department of Insurance, Securities, and Banking (DISB) published a Bulletin in late April reminding those who service student education loans in the District of Columbia of their obligation to file an annual report. The DISB has now released the required forms for both the 2018 and 2019 filings.

In an email to servicers, the Commissioner explained that the DISB was waiting to release the 2018 annual report form until Student Loan Servicing Alliance v. District of Columbia, et al. was resolved. Both the DISB and SLSA have now withdrawn their appeals of the decision. The Bulletin also explains that because of the litigation, the 2018 annual report form is now due by June 15, 2019 and no late fees will be assessed based upon the initial statutory deadline of January 30. The letter also informed servicers that the information collected in the annual report will be used to generate the annual assessment that is due on November 15, 2019. The 2019 annual report form is due by January 30, 2020, consistent with Section 3014 of the DISB regulations.

The annual report forms request information regarding the total number of borrowers and dollar amount of loans serviced in the District of Columbia, as well as the total number of borrowers and dollar amount of loans involving: delinquencies of 30 to 90 and 91 to 180 days; collections; modifications; deferments; loans sold, assigned, or transferred to the licensee; and loans sold, assigned, or transferred from the licensee.

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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...

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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, advertising and marketing, application processing, privacy, disclosure, pricing, substantive terms, servicing, collection, portfolio sales, and securitization. His regulatory practice includes preparing clients for banking agency and CFPB compliance examinations and assisting in the defense of attorney general investigations and banking agency and CFPB enforcement actions. His clients have ranged from a multibillion-dollar bank holding company, to one of the nation's largest residential mortgage lenders, to a leading provider of financial institution forms and documentation. Mr. Culhane is a member of the firm's Fair Lending Task Force.

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