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Financial Services Law Insights and Observations


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  • West Virginia creates regulatory sandbox program

    State Issues

    On March 24, the West Virginia governor signed HB 4621, which creates a state fintech regulatory sandbox program through the state’s Division of Financial Institutions (Division) that allows participants to temporarily test innovative financial products or services on a restricted basis without requiring a license under West Virginia law. Under the program, approved applicants will have 24 months from the date an application is approved to test their product or service within the state without being subject to state laws and regulations that normally would regulate such products or services, unless the Division determines otherwise. HB 4621 outlines requirements for participants, which include specific state consumer protection laws, time limitations, and reporting requirements. Additionally, the Division, upon written notice, may end a participant’s participation in the program at any time and for any reason. The program allows participants to request an extension of time up to 12 months after the end of the regulatory sandbox testing period in order to obtain a license or other authorization required by the law to continue to offer the product or service. The act takes effect on June 5.

    State Issues State Legislation Fintech Regulatory Sandbox West Virginia

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  • West Virginia issues stay at home order

    State Issues

    On March 23, the West Virginia governor issued a stay at home order requiring non-essential businesses and operations to temporarily cease operations. Essential businesses and operations include financial and insurance institutions, including banks and banking services such as ATM services, currency exchanges, consumer lenders, credit unions, appraisers, title companies, financial markets, trading and futures exchanges, payday lenders, affiliates of financial institutions, professional debt collectors and related creditor service workers, workers engaged in payment clearing and settlement, wholesale funding, and capital markets activities, entities that issue bonds, related financial institutions, institutions selling financial products, insurance companies, underwriters, agents, brokers, and related insurance claims and agency services. Additionally, essential businesses and operations include those businesses that sell, manufacture, or supply other essential businesses and operations with the support of materials necessary to operate. The order becomes effective at 8:00 PM on March 24, 2020, and remains in effect until terminated by subsequent executive order.

    State Issues West Virginia Covid-19 Consumer Lending Consumer Finance

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