Banking Committee
JOINT FAVORABLE REPORT
Bill No.: SB-848
AN ACT IMPLEMENTING THE DEPARTMENT OF BANKING'S
RECOMMENDED CHANGES TO THE BANKING STATUTES CONCERNING
Title: FINANCIAL INSTITUTIONS AND CONSUMER CREDIT LICENSES.
Vote Date: 3/9/2021
Vote Action: Joint Favorable Substitute
PH Date: 2/18/2021
File No.: 127
Disclaimer: The following JOINT FAVORABLE Report is prepared for the benefit of the
members of the General Assembly, solely for purposes of information, summarization and
explanation and does not represent the intent of the General Assembly or either chamber
thereof for any purpose.
SPONSORS OF BILL:
Banking Committee
REASONS FOR BILL:
Requested by Department of Banking. Focuses on creating an easier and fairer system to
help financial institutions and protect members of the community from being taken advantage
of. It intends to reduce regulatory steps that causes more complications by allowing for
consolidated audit reports to be submitted and removing the need for the Commissioner to
endorse a certificate of incorporation for a Connecticut Credit Union. By reducing these
unnecessary steps, it will allow for more ease and less regulatory burdens on financial
institutions.
Substitute language was later added as the bill was amended to include language from SB-
849. SB-849, as well, was raised per the recommendations from the Department of Banking.
It includes changes regarding consumer credit licenses. The substitute language allows for a
more fair and equitable system by extending the lead generator license exemption to
federally insured banks and credit union employees. As well, this addition to SB-848 protects
communities as it ensures that individuals cannot be taken advantage of through the change
of control of licenses to lenders. Allowing only those that are licensed to purchase debt in
Connecticut and strengthening the oversight of the Department of Banking, communities are
safer from potential financial burdens.
RESPONSE FROM ADMINISTRATION/AGENCY:
Matt Smith, Director of Government Affairs at the Department of Banking The
Department of Banking supports SB-848 as it follows their recommended changes to the
financial institutions and consumer credit licenses. They find that it will reduce regulatory
burden by simplifying steps and create less restrictions in addition to clarifying language,
creating new framework, and fixing technical changes to statues
NATURE AND SOURCES OF SUPPORT:
Jeff Gentes, Connecticut Fair Housing Center The Connecticut Fair Housing Center
supports SB-849 before it became a part of SB-848. They state that individuals will purchase
tax liens from municipalities and later foreclose on homeowners after claiming high interest
charges. They believe the changes to consumer credit licenses will help protect marginalized
communities that are disproportionally affected by these practices.
Tom Mongellow, Art Corey, and Fritz Conway, Connecticut Bankers Association - The
CBA specifically supported SB-849, Section 2(b)(5)(G), before it was added to SB-848s
Section 6, regarding mortgage lead generators. They believe this bill provide a more
complete exemption as before it did not cover all lead generator activities that may occur
between a bank or credit union and their affiliates, and this amendment will ensure and
clarify that the existing exemption covers all affiliates that engage in these activities.
NATURE AND SOURCES OF OPPOSITION:
John C. Dilorio First Alliance - opposes SB-849s language and finds that repealing and
replacing 36a-485 and 36a-486 leaves Connecticut with confusing licensing laws, that
expose licensees to severe hidden risk, and leaves Connecticut consumers vulnerable.
Dilorio believes that the language of the bill should be amended to institute certain changes
such as ensuring all Mortgage Loan Originators are subject to same qualification and
licensing requirements, adding additional mandatory ethic and fraud training, removing
numerous exceptions to the Lead Generator License, and adopt TRID definition of
Application for all MLOs in context of SAFE. Some other recommendations include not
allowing Shared Appreciation Agreements to be utilized within the state, to codify in law that
Advisory Opinion Letters do not have the force of law and cannot be used as a basis for
enforcement against any entity, and altering definitions of specific language as natural
person is used to define both a Person and an Individual and two terms should not share
a definition.
Reported by: Jennifer Mouser / Dawn Marzik Date: 3/25/2021
Page 2 of 2 SB-848


Statutes affected:
Raised Bill:
BA Joint Favorable Substitute:
File No. 127:
Public Act No. 21-138: