Update: Connecticut to License US Locations Only
Public Act 18-173 was recently signed into law in the state of Connecticut and will be effective October 1, 2018. The Act makes substantive changes to The Banking Law of Connecticut including the laws that govern Consumer Collection Agencies. As it relates to licensing, section 36a-801 of the Connecticut General Statutes have been amended to read that, “Any activity subject to licensure shall be conducted from an office located in a state, as defined in section 36a-2.”
Section 36a-2 defines state to mean any state of the United States, District of Columbia, any territory of the United States, Puerto Rico, Guam, American Samoa, the trust territory of the Pacific Islands, the Virgin Islands and the Northern Mariana Islands. In short, the Connecticut Department of Banking will no longer issue consumer collection agency licenses to an office located outside the United States or it territories.
The Act also provides some clarity around licensing for debt buyers by specifically including the term debt buying in the definition of a consumer collection agency and defining debt buying as collecting or receiving payment on any account, bill or other indebtedness from a consumer debtor for such person’s own account if the indebtedness was acquired from another person and if the indebtedness was either delinquent or in default at the time it was acquired.
Connecticut is not putting into place any licenses currently that will be revoked in October.