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1. Delaware Enacts Banking Modernization and Digital Asset Legislation
On July 6, Delaware Governor Matt Meyer signed into law Senate Bills 16, 18, and 19 with the aim of modernizing Delaware’s financial services framework by establishing clear, consumer-focused regulatory standards for banking, money transmission, virtual currency, and stablecoins.
- Senate Bill 16 (the Delaware Banking Modernization Act of 2026) updates the banking code to address digital assets, modernize corporate governance and organizational requirements, facilitate interstate trust operations, and expand the regulatory authority of the State Bank Commissioner.
- Senate Bill 18 (the Delaware Money Transmission and Virtual Currency Modernization Act) repeals the state’s prior money transmission law and replaces it with a more modern licensing and oversight framework for money transmitters and virtual currency businesses, including licensing qualifications, financial strength standards, and customer protections.
- Senate Bill 19 (the Delaware Payment Stablecoins Act) establishes a licensing and oversight framework for payment stablecoin issuers, including requirements for one-to-one reserve backing, monthly public attestations, and anti-money laundering compliance. The act is intended to be aligned with the federal GENIUS Act.
All three acts are effective as of signing, but their respective substantive provisions will become operative after one year or upon the State Bank Commissioner’s earlier publication of notice that final implementing regulations have been adopted.
2. Illinois Enacts Buy Now Pay Later Licensing Law
On June 25, Illinois Governor J.B. Pritzker signed into law Senate Bill 3561, establishing a licensing and oversight regime for buy now pay later (BNPL) providers and regulating providers of BNPL loans and entities engaged in arranging, facilitating, purchasing, or servicing them. The law also sets underwriting and repayment standards for BNPL products, imposes disclosure and servicing requirements, and contains broad anti-evasion provisions. Unless a later date is established by regulation, compliance is not required until January 1, 2028.
3. Vermont Enacts Commercial Financing Licensing and Disclosure Requirements
On June 16, Vermont enacted H. 648, a wide-ranging bill that impacts many of the state’s financial services laws. Section 60 of the bill establishes licensing and disclosure requirements for providers who offer or solicit sales-based financing or factoring transactions. Depository institutions, governmental entities, seller financing, and certain transactions of $1,000,000 or more that are not for personal, family, or household use are exempt. Providers will need to provide written disclosures, including an estimated APR. Section 60 also restricts automatic payment practices, confessions of judgment, certain arbitration practices, choice of law, and choice of venue. Section 60 will become effective July 1, 2027.
4. Federal Reserve Proposes Amended AML/CFT Program Requirements for Supervised Banks
On July 9, the Board of Governors of the Federal Reserve System (Federal Reserve) published in the Federal Register a notice of proposed rulemaking to amend its anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements for supervised banks. Among the most significant changes, the proposed rule would: (1) adopt the expectation that AML/CFT programs be risk-based, directing greater resources toward higher-risk customers and activities; (2) require Federal Reserve-supervised banks to review FinCEN’s AML/CFT priorities and incorporate them into their risk assessments where appropriate; and (3) distinguish between a bank’s duty to “establish” a program and its duty to “maintain” one, such that once a program is established, Federal Reserve supervision and enforcement would focus on significant or systemic failures to implement the program. Comments on the proposal are due September 8.
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From Uncertainty to Opportunity: FINRA Provides Long-Awaited Clarity on Personal-Services Entity Compensation
In November 2025, U.S. Securities and Exchange Commission (SEC) staff issued a no-action letter permitting registered representative-owned personal services entities to receive transaction-based compensation without broker-dealer registration, subject to conditions. On June 9, FINRA issued Regulatory Notice 26-12, providing detailed guidance on the application of FINRA rules to broker-dealer arrangements structured in accordance with the SEC’s no-action relief. The notice does not apply new requirements beyond those in the no-action letter. To read more, click here.
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