SearchLending Compliance & Fair Lending

The complete guide · October 2026

State lending law research, explained.

A lender that makes loans in many states lives under many rulebooks. Each state sets its own top interest rate, its own fee limits and its own exceptions, and changes them on its own calendar. Before a product team prints one late fee on every contract, someone has to look up the rule in each state, read the exact words, work out what they allow on the actual loan, and write down where the answer came from. That is state lending law research.

This guide is for anyone who asks, answers or acts on "what does this state allow?": compliance analysts and officers, in-house counsel, product managers, licensing and collections teams, fintech and bank-partnership leaders, and anyone deciding whether software should do part of the work. It explains the law in general terms and is not legal advice.

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A quick example · fictional

Imagine you are the senior compliance analyst at Larkhaven Financial, a consumer lender licensed in all 50 states and DC. It is Tuesday, October 13, 2026, at 9:12 in the morning. Product is launching the Flex Installment Loan in February 2027, and the product manager wants one late fee to print on every contract. The company's fee policy, CP-14 § 4.2, says: "5% of the late installment, minimum $15."

You take the product's reference loan: $5,000 over 36 months, a monthly payment of $182.40. Five percent of that is $9.12, so the $15 minimum is what the policy would charge on every late payment. The question is where a state allows less.

Texas is a good first test, and it shows why the exact section matters. A $5,000 Texas consumer loan falls under the state's general consumer-loan rules, where Tex. Fin. Code § 342.203 lets the contract add a default charge once a payment is more than 10 days late, of no more than "five cents for each $1 of a scheduled installment." A different Texas rule, for small loans only, allows "5% of the scheduled installment amount or $10, whichever is greater." Read the wrong one and you get the wrong cap.

Larkhaven policy · CP-14 § 4.2
Rule
5%, minimum $15
5% of $182.40
$9.12
Charged
$15.00
Where
Every state
Texas · Fin. Code § 342.203(d)
Rule
5¢ per $1 of the installment
On $182.40
$9.12
Most allowed
$9.12
When
After the 10th day
$15.00 under the policy$9.12 in Texas$5.88 too much on every late payment there.

Texas is one state of 51. In the case's research run, the answer for every jurisdiction came back with its citation, and the policy's $15 minimum sat above the cap in 14 of them, by $1.50 to $10.00 a payment. Counsel signed a "lesser of" exception for those 14 the same morning. (The other states' figures here come from the case's sample rule library; Part A gives real rules, each cited.)

Careful state-law research finds the states where one national fee breaks the local cap, before the contract goes to print.

State lending law research guide
Part A · Understand it

Fifty-one rulebooks for one loan: rate caps, fee limits, exportation, true lender and the 2026 changes

What state lending law research covers, which rules reach which lenders, how the caps differ, what changed between 2023 and October 2026, how answers go stale, and what a wrong answer has cost lenders. No product is named in this part. It explains the law in general terms and is not legal advice.

01 · In plain words

State lending law research in plain words: one question, a different answer in every state

In the United States, each state writes its own consumer lending law. One state lets a lender charge 36% a year on a small loan; the next allows far more; a third sets no limit at all. Fees work the same way. A late fee, a fee for a bounced payment, a fee for paying by phone: each has its own rule, or none, depending on the state, the kind of loan and the size of the loan. Federal law sits on top and changes who has to follow which state's rules.

A lender that lends in many states therefore keeps asking the same kind of question: what is the most we may charge, what must we tell the borrower, how long must we wait, and does this rule apply to us at all? Product teams ask before they launch. Collections asks before it changes a script. Marketing asks before it prints a rate. The compliance team answers, usually one state at a time.

Answering well takes four things. The right section of law for the lender and the product, since one state can have three chapters that each govern a different loan. The exact words, because "5% or $10, whichever is greater" and "whichever is less" give different numbers. The arithmetic on the real loan, because a percentage cap has no value until it meets a payment. And the date: the answer is true as of the version of the text that was read, and states amend their rules on their own calendars.

The finished answer is usually a table with one row per state, often 51 rows with DC, each with its citation. In-house counsel reviews it before anyone relies on it. The hard part is keeping it true: knowing which answers, policies and contracts rest on which sections, so that when a section changes, the people who relied on it hear about it.

The life of one state-law question, in five steps

  1. Someone asksProduct wants one late fee for a new installment loan: "What is the most we can charge?"
  2. The facts are fixedWhich product, secured or not, the loan size and payment, the lender's charter, the states in scope.
  3. Every state is researchedThe controlling section found and read, the cap worked out on the payment, amendments and pending cases checked, each answer cited. This guide is about this step.
  4. Counsel reviews, policy followsCounsel reads the answer and signs any exception to the company's own fee policy.
  5. The answer has to stay trueEvery later amendment, court ruling or index move can make it wrong, and someone has to notice.

The example at the top of the page is fictional. The rules cited in this part are real, each with its source.

Four surprises in state usury and fee law

The same $500 loan can be capped at 16% or 305%

On a $500 six-month loan, the highest APR a licensed lender may charge runs from 16% in North Carolina to 305% in Mississippi, and Delaware and Missouri set no cap at all, according to the National Consumer Law Center's December 2025 chart.1

Who lends matters before where

A national bank may charge the rate its home state allows, late fees included, to borrowers anywhere. A state-licensed lender must follow each borrower's state in full. The same question has different answers for the two.2

Some answers hang on a court

Colorado's 2023 law limiting what out-of-state state banks may charge Coloradans has been blocked for the challengers' members since June 2024. The full Tenth Circuit set argument for August 18, 2026, and we found no ruling as of October 31, 2026.3,4

Nobody counts how often the rules change

We found no government or academic count of state consumer-lending rule changes. A single Florida section, the one that sets consumer finance rates and fees, was amended in 2013, 2018, 2022 and 2024.5

Usury limit, exportation, opt-out, true lender: the terms defined

Usury limit

The highest interest rate a state's law allows. Many states set several: a general limit, and higher ones for licensed lenders.

Rate exportation

A bank charging borrowers in other states the rate its home state allows, under federal law.

Opt-out

A state using a 1980 federal law to say out-of-state state banks must follow its own rates on loans made there.

True lender

A test for whether a bank or the company behind its loan program is the real lender, and so whose rate limits apply.

Fourteen terms are defined in the glossary.

02 · What the research covers

The questions a multistate lender asks every week, and the layers of law each answer must read

In shortMost questions fall into six families: rates, fees, disclosures, conduct, licensing triggers, and whether a rule reaches the lender at all. Each answer reads several layers of law at once: statute, regulation, regulator guidance and the court and enforcement record. A free regulator-verified survey covers the broad strokes; a lender's own product questions start where it stops.

Price

Rates and fees

The highest APR or interest rate by loan size, late and returned-payment fees, origination fees, prepayment penalties, how a fee counts toward the rate.

Words

Disclosures and notices

What a contract or offer must say, notices before a fee or a repossession, the cost of a small-business financing offer stated as a yearly rate.

Conduct

Collection and fair dealing

Contact limits, cure periods, unfair and abusive practices under state law, state fair-lending rules.

Reach

Does it apply to us?

Bank or licensee, exportation, opt-outs, true-lender tests, loans bought from a bank. Section 03 covers it.

Permission

Licensing triggers

Whether a loan of a given size or kind needs a state license. Licenses themselves are a separate subject and a separate guide.

Time

What changed, and when it applies

Amendments, effective dates, which loans a change reaches, indexed caps that move without an amendment.

Statute, regulation, guidance, courts: the layers behind a state-law answer

LayerWhat it givesWhere it isA trap
StatuteThe rate, the fee, the condition, the penaltyThe state's code, as amended by session lawsOne state can have several chapters for different loans: Florida sets consumer finance charges in one chapter and a general 18% limit for other lenders in another5,6
RegulationDetail, forms, calculationsThe state's administrative code and registerTexas has a separate default-charge rule for small loans that does not govern larger ones7,8
GuidanceThe regulator's reading: FAQs, bulletins, opinion lettersRegulator and attorney general websitesWithdrawn or replaced without notice to the people who relied on it
Courts and ordersWhose law applies, what a word means, what a breach costsCourt dockets, consent orders, settlementsA pending case can change the answer on the day it is decided9

The free starting point, and its limits

Most teams start with the Conference of State Bank Supervisors' 50-State Survey of Consumer Finance Laws. It covers "consumer loans" as each state defines them, licensing and lending requirements, mandated loan terms and fee limits, and its information "has been reviewed and verified by the appropriate state regulatory authority." Its limits are stated as plainly: "payday, title lending, retail installment lending, and other more targeted license types are not included," and "State information will be updated on an annual basis."10 A lender with a retail installment product, an indexed cap or a question about this month's text has to go further.

Fee and rate questions come up often and cost the most when they are wrong

Six families of state-law questions, by how often a multistate consumer lender asks and what a wrong answer can cost

Cost of a wrong answer →
Check when asked
Most care
Keep on file
Keep a table
Rate capsFee limitsDoes it apply to usLicensing triggersDisclosuresCollection conduct
How often it is asked →

Illustrative · replace with your own numbers · Positions are our judgment for a consumer installment lender; no public data ranks these questions. Your own question log is the better measure.

Show the numbers
ItemHow often it is asked (0–1)Cost of a wrong answer (0–1)
Rate caps0.620.66
Fee limits0.800.55
Does it apply to us0.250.78
Licensing triggers0.150.55
Disclosures0.550.24
Collection conduct0.760.12
03 · Who the law reaches

Banks, licensed lenders and bank partnerships: which state's limits reach each kind of lender

Status as of October 2026

In shortBefore reading any state's cap, place the lender. National banks charge their home state's rate, fees included, anywhere. State-chartered insured banks may do the same unless the borrower's state has opted out. State-licensed lenders follow each borrower's state in full. Bank partnership programs sit in between, decided case by case under true-lender tests.

National banks: interest is what the home state allows, and late fees count as interest

The National Bank Act lets a national bank charge the interest its home state allows on loans to borrowers anywhere. The OCC's rule defines that interest broadly, including "numerical periodic rates, late fees, creditor-imposed not sufficient funds (NSF) fees" and other charges. It also says the federal definition "does not change how interest is defined by the individual states" for state-law purposes, and that permissible interest "shall not be affected by the sale, assignment, or other transfer of the loan."2

For other state laws, the Supreme Court held in 2024 that the National Bank Act preempts a state law only where it "prevents or significantly interferes" with a national bank's powers, a test applied case by case.11

State banks: the same power, unless the borrower's state opts out

Section 521 of the Depository Institutions Deregulation and Monetary Control Act of 1980 (DIDMCA), codified at 12 U.S.C. § 1831d, lets an FDIC-insured state-chartered bank charge the greater of one point over the 90-day commercial paper rate or "the rate allowed by the laws of the State, territory, or district where the bank is located." Section 525 lets a state say it "does not want this section to apply with respect to loans made in such State."12 The FDIC's rule fixes the answer at origination: whether interest is permissible "is determined as of the date the loan was made," unaffected by "a change in State law" or a later sale of the loan.13

Licensed lenders: every borrower's state, in full

A state-licensed nonbank lender gets no federal rate power. Each borrower's state applies: its rate cap, its fee caps, its waiting periods and its conditions. Florida shows how sharp the line is. A person lending $25,000 or less without the consumer finance license may not charge more than 18% a year, and "A loan for which a greater rate of interest or charge than is allowed by this chapter has been contracted for or received, wherever made, is not enforceable in this state."6 The license lifts the limit to 36% a year on the first $10,000, 30% on the next $10,000 and 24% up to $25,000.5

Partnerships: who is the true lender?

When a bank originates a loan that a nonbank markets, services or buys, the question is who the lender really is. In 2020 the OCC adopted a rule that would have settled it for national banks; Congress disapproved it, and the rule "shall have no force or effect," by a resolution approved June 30, 2021.14 Since then the answer is again for state law and the courts (section 07).

How far a borrower's state rules reach depends first on the kind of lender

Does the borrower's state rule bind the lender? A general reading, consumer installment loans not secured by a home

NoContested or case by caseYes
Rate capFee capsConduct and collection rulesNational bankNoNoContested or case by caseOut-of-state state bank, state that has not opted outNoNoContested or case by caseOut-of-state state bank, Colorado or OregonContested or case by caseContested or case by caseContested or case by caseNonbank lending through a bank partnerContested or case by caseContested or case by caseYesState-licensed nonbank lenderYesYesYes

Our reading of the sources 2,12,11,9,15,16,17 · Our reading of the federal texts and the pending cases, as of October 31, 2026. Fees count as interest for national banks under 12 CFR 7.4001; for state banks the treatment of a particular fee can turn on the facts. Your counsel decides for your charter and product.

Show the numbers
Rate capFee capsConduct and collection rules
National bankNoNoContested or case by case
Out-of-state state bank, state that has not opted outNoNoContested or case by case
Out-of-state state bank, Colorado or OregonContested or case by caseContested or case by caseContested or case by case
Nonbank lending through a bank partnerContested or case by caseContested or case by caseYes
State-licensed nonbank lenderYesYesYes
04 · Rate caps and the 36% line

Usury limits by state in 2026: the 36% APR caps, the states above them and the two with none

Status as of October 2026

In shortAlmost every state caps the APR on a small installment loan from a licensed lender, but the caps run from 16% to 305% on the same $500 loan, and they fall as loans get larger. Twenty jurisdictions sit at 36% or below. Several states have adopted all-in caps near 36% since 2021, and some caps follow a market rate, so they move without any new law.

The National Consumer Law Center surveys the highest APR, fees included, that a licensed nonbank lender may charge on three closed-end unsecured loans in every state. Its December 2025 chart counts "45 states and DC" that cap the rate on a $500 six-month loan, "43 states plus DC" for a $2,000 two-year loan and "42 states plus DC" for a $10,000 five-year loan. Idaho, Utah and Wisconsin only prohibit unconscionable rates on the $500 loan; Delaware and Missouri have "no limit whatsoever."1

On the same $500 loan, the legal ceiling runs from 16% to 305%

Highest APR, fees included, on a $500 six-month loan from a licensed lender, selected states

North Carolina16%
New York25%
Illinoisall-in cap since 202136%
Oregon36%
California45%
Florida52%
Colorado78%
Texas116%
Virginia129%
Ohio145%
Mississippi305%

Source 1 · Rates current as of September 2025. Delaware and Missouri set no cap; Idaho, Utah and Wisconsin prohibit only unconscionable rates.

Show the numbers
StateMaximum APR
North Carolina16%
New York25%
Illinois36%
Oregon36%
California45%
Florida52%
Colorado78%
Texas116%
Virginia129%
Ohio145%
Mississippi305%
Twenty jurisdictions cap a $500 loan at 36% or less

All 50 states and DC, by the highest APR allowed on a $500 six-month loan

36% or less (19 states and DC): 20Above 36%, up to 60%: 13Above 60%: 13Unconscionability only: 3No cap: 2
51jurisdictions
  • 36% or less (19 states and DC)20
  • Above 36%, up to 60%13
  • Above 60%13
  • Unconscionability only3
  • No cap2

Source 1 · Our count from NCLC's state-by-state chart.

Show the numbers
PartValue
36% or less (19 states and DC)20
Above 36%, up to 60%13
Above 60%13
Unconscionability only3
No cap2
The bigger the loan, the lower the typical cap

Median maximum APR in states that cap rates, by loan

39.5%$500, 6 months
34%$2,000, 2 years
27%$10,000, 5 years

Source 1

Show the numbers
LoanMedian cap
$500, 6 months39.5%
$2,000, 2 years34%
$10,000, 5 years27%

Why 36% keeps coming up

NCLC calls 36% "a widely-accepted maximum rate for small loans," and adds that for larger loans "36% is a very high rate." Its arithmetic: raising the rate from 25% to 36% "adds over $4,000 to the cost of a $10,000, five-year loan."1 The same organization told Rhode Island legislators in 2025 that going from 21% to 36% on that loan adds $5,448 in interest.16

Moving a $10,000 five-year loan from 21% to 36% adds about $5,450 of interest

Total interest paid over 60 monthly payments, simple amortization

21% APR$270.53 a month$6,232
25% APR$293.51 a month$7,611
36% APR$361.33 a month$11.7K

Our reading of the sources 1,16 · Our amortization arithmetic; it matches NCLC's 'over $4,000' (25% to 36%) and $5,448 (21% to 36%).

Show the numbers
RateInterest paid
21% APR$6,232
25% APR$7,611
36% APR$11.7K

Recent all-in caps and anti-evasion laws

StateWhat it didWhen
IllinoisPredatory Loan Prevention Act: a 36% APR cap, counted "all in" by the Military Lending Act method, on consumer loans under $40,000, with an anti-evasion test for a company holding the "predominant economic interest" in a bank's loan182021
MinnesotaA 50% all-in APR cap for small-loan and short-term lenders, an ability-to-repay duty above 36%, and anti-evasion rules that apply "regardless of whether a person has a physical location in Minnesota"19January 1, 2024
New MexicoHB 132: a 36% APR cap on loans of $10,000 or less from lenders other than insured banks and credit unions (a fee of up to 5% on loans of $500 or less sits outside the APR), with an anti-evasion test for a company holding the predominant economic interest in a loan20Signed March 1, 2022; in force January 1, 2023
ColoradoOpted out of rate exportation for consumer credit made or renewed in the state21July 1, 2024 (enforcement blocked, section 06)
OregonOpted out for consumer finance loans of $50,000 or less, so out-of-state state banks meet Oregon's 36% cap15June 5, 2026 (challenged, section 06)

Caps that move without a new law

Some caps are tied to a market rate. California's Financing Law caps consumer loans of $2,500 to under $10,000 at 36% a year plus the federal funds rate in effect on the first day of the month before the loan is made, as published in the Federal Reserve's H.15 release (Cal. Fin. Code § 22304.5).22 The California regulator fined one lender $1 million in October 2025 and had it return $218,705.38 to borrowers for fees and interest above those limits.23

With the effective federal funds rate at 3.88% on October 29, 2026, the cap would sit near 39.9%.24 Washington's general usury limit is the higher of 12% or "four percentage points above" a 26-week Treasury bill yield, reset monthly from an auction.25 An answer saved as a single number is right for one period only; it should be saved as the formula with the date it was worked out.

05 · Late fees and other charges

Late fee limits by state: why "the most we can charge" has four parts and a payment

In shortA fee rule has an amount, a form (flat, a percentage, or the greater or lesser of the two), a wait before it may be charged, and conditions such as a written agreement. A percentage rule has no value until it meets a payment. Work every state's rule out on the same reference loan, and check that the section read is the one that governs that loan.

The four parts of a fee rule

1 · Amount and form

"$15" or "5%, or $10 if greater"

A flat amount, a percentage, or the greater or lesser of the two. The word "greater" or "less" changes the answer.

2 · The wait

How late before a fee

Florida allows its fee only on a payment "in default for at least 12 days"; Texas and Colorado use ten days.5,8,26

3 · Conditions

Agreed in writing, once per payment

Florida requires the charge to be "agreed upon, in writing, between the parties before imposing the charge"; Texas allows the default charge only once on the same installment.5,8

The fourth part is scope: which loans the rule covers. Florida sets different caps for payments due monthly ($15), semimonthly ($7.50) and every two weeks ($7.50 or $5, depending on how many payments fall in the month).5

Texas sets one default charge for its general consumer loans, "five cents for each $1 of a scheduled installment," and a separate one for small loans, where a lender may contract for "5% of the scheduled installment amount or $10, whichever is greater."8,7 The small-loan rule applies only up to an indexed maximum cash advance built on a $100 reference base: $920 for loans made from July 1, 2026 to June 30, 2027, or $1,840 for the larger-advance loans of § 342.259.27,28 A $5,000 loan is far above both.

The same payment under four real rules

On one $182.40 payment, four real state rules allow between $9.12 and $15

Most a lender may charge for one late monthly payment of $182.40, under each rule's own conditions, against a policy of 5% with a $15 minimum

Texas, general consumer loan: 5¢ per $1after the 10th day$9.12
Texas, small loan: 5% or $10, the greaterapplies only to small loans$10
Florida consumer finance: $15 a monthafter 12 days, agreed in writing$15
Colorado: $15, loan not secured by landafter ten days$15
A policy of 5%, minimum $15breaks the first two rules$15

Our reading of the sources 8,7,5,26 · Our arithmetic on the rule text. A $5,000 loan with a $182.40 payment would not qualify for Texas's small-loan rule; it is shown to make the point that the section matters.

Show the numbers
RuleMost allowed
Texas, general consumer loan: 5¢ per $1$9.12
Texas, small loan: 5% or $10, the greater$10
Florida consumer finance: $15 a month$15
Colorado: $15, loan not secured by land$15
A policy of 5%, minimum $15$15

Five percent of $182.40 is $9.12. Under Texas's general rule that is the cap. A policy that charges "5%, minimum $15" charges $15 there, $5.88 more than the law allows on every late payment. In Florida and Colorado the same $15 sits exactly at the cap, as long as the lender also waits the 12 or ten days and has the written agreement. A one-line table reading "Florida: $15" is right about the amount and silent on the wait, which is where a fee charged on day 11 goes wrong.

Returned-payment and other fees follow their own rules

A returned-payment fee usually sits in a different section from the late fee, with its own amount. Florida's consumer finance act allows "a bad check charge of not more than the greater of $20 or an amount equal to the actual charge made to the lender."5 Texas sets its dishonored-payment fee by reference to its commercial code.29 A lender's fee schedule therefore needs a separate researched answer for every fee, in every state.

Overcharges have a refund clock. In Florida, "In the event of a bona fide error, the licensee shall refund or credit the borrower with the amount of the overcharge immediately but within 20 days after the discovery of such error."5 Once research shows a fee is above a state's cap, the time to fix it may already be running.
06 · Exportation and the DIDMCA opt-outs

Interest rate exportation and the DIDMCA opt-outs: Colorado's 2023 law, the Tenth Circuit and Oregon's 2026 law

Status as of October 31, 2026

In shortIowa has long opted out of DIDMCA's rate exportation. Colorado opted out from July 1, 2024, but a court has blocked enforcement against the challengers' members since June 2024; the full Tenth Circuit set argument for August 18, 2026, and we found no ruling by October 31. Oregon opted out for consumer finance loans from June 5, 2026 and was sued ten days later. More states have bills pending.

Who sets the rate on a bank-originated loan: from DIDMCA in 1980 to two cases pending in 2026
  1. 1980DIDMCA

    Section 521 lets state banks export home-state rates; section 525 lets a state opt out.

  2. Jun 30, 2021OCC true-lender rule voided

    Congress disapproves the October 2020 rule.

  3. 2021Illinois 36% all-in cap

    With an anti-evasion test.

  4. Jun 5, 2023Colorado opts out

    HB23-1229 signed; opt-out from July 1, 2024.

  5. Jun 2024Colorado blocked

    District court enjoins enforcement for the trade groups' members.

  6. Nov 10, 2025Panel reverses, 2–1

    A loan is 'made in' Colorado if the lender or the borrower is there.

  7. Apr 2, 2026Rehearing granted

    Full court vacates the panel judgment; the injunction is back.

  8. Apr 7, 2026Oregon opts out

    HB 4116 signed; effective June 5, 2026.

  9. Jun 15, 2026Oregon sued

    Three trade groups; injunction motion July 9.

  10. Aug 18, 2026En banc argument

    Tenth Circuit, Colorado case.

  11. Oct 31, 2026Both pending

    No en banc ruling and no Oregon injunction ruling found.

Source 12,14,18,21,19,3,9,30,31,15,32,4

Show the numbers
WhenWhat
1980DIDMCA
Jun 30, 2021OCC true-lender rule voided
2021Illinois 36% all-in cap
Jun 5, 2023Colorado opts out
Jun 2024Colorado blocked
Nov 10, 2025Panel reverses, 2–1
Apr 2, 2026Rehearing granted
Apr 7, 2026Oregon opts out
Jun 15, 2026Oregon sued
Aug 18, 2026En banc argument
Oct 31, 2026Both pending

What "made in" means is the whole case

Colorado's law opts the state out for "consumer credit transactions" made or renewed on or after July 1, 2024, so Colorado's Uniform Consumer Credit Code rates apply.21 Industry trade groups sued. The district court read a loan as "made where the lender is located and performs its lending functions," and enjoined Colorado in June 2024. A Tenth Circuit panel reversed 2–1 on November 10, 2025, holding that a loan is made in an opt-out state when either the lender or the borrower is located there.33,30

On April 2, 2026 the full court granted rehearing and vacated that judgment, "effectively restoring the district court's preliminary injunction."9 Twenty-one states, led by Utah, filed a brief for the challengers on June 4, 202634, and argument was set for August 18, 2026.4

Oregon: a narrower opt-out, the same fight

Oregon's HB 4116, signed April 7, 2026, opts out for consumer finance loans made in the state.31 It took effect June 5, 2026, and targets loans of $50,000 or less that out-of-state state banks make to Oregon borrowers above Oregon's 36% cap. AFSA, the National Association of Industrial Bankers and the Online Lenders Alliance sued on June 15, 2026, arguing the law is preempted and burdens interstate commerce.15 They moved for a preliminary injunction in the District of Oregon on July 9, 2026.32 We found no ruling as of October 31, 2026.

Bills to watch

In early 2026 Rhode Island reintroduced a combined opt-out and true-lender bill (SB 2206 on January 23, HB 7850 on February 27), New York proposed a true-lender bill (A 10133, February 3), and Wisconsin had a true-lender bill pending since December 2025.30 An opt-out leaves a national bank's own rates alone: section 525 reaches only the state-bank power in section 521, and national banks lend under the National Bank Act.12 True-lender bills can still reach the companies that partner with any bank.

How to write a Colorado or Oregon answer today. Say which lender it covers, state the Colorado or Oregon rule, state that enforcement against out-of-state state banks is blocked (Colorado) or challenged (Oregon), name the case and the date checked, and set the answer to be reviewed the day either court rules.
07 · True-lender laws

True lender laws by state: when the company behind a bank's loan has to follow state rate caps

Status as of October 2026

In shortWith the OCC's rule gone, states decide who the true lender is. At least six states have written tests into statute since 2021, most built on who holds the "predominant economic interest." Courts still go both ways: in May 2026 a California trial court found a bank was the true lender in a partnership program, and the state appealed.

Critics call the arrangement "rent-a-bank": a nonbank designs and runs a loan program, a bank in a state with no rate cap originates the loans, and the nonbank buys them or most of their revenue. NCLC's 2025 testimony describes nonbank lenders that "typically" design and own the program, process applications, approve loans, collect payments and take "up to 96%" of the revenue, and lists Connecticut, Illinois, Maine, Minnesota, New Mexico and Washington among the states that have codified the true-lender doctrine "since 2021,"16 a list it repeated in April 2026.35

The statutes: Illinois, 815 ILCS 123/15-5-15 (2021); Maine, 9-A M.R.S. § 2-702 (Public Law 2021, chapter 297); New Mexico, N.M. Stat. § 58-15-3 (in force January 1, 2023); Connecticut, Conn. Gen. Stat. § 36a-556(d) (Public Act 23-126, in force October 1, 2023); Minnesota's 2023 consumer small-loan and short-term loan amendments (in force January 1, 2024); and Washington's Consumer Loan Act, chapter 31.04 RCW, as amended by SSB 6025 in 2024.36,37,19,38 Industry groups dispute the label and the economics; the courts decide each program on its facts.

What the tests look at

Economics

Predominant economic interest

Who keeps most of the revenue and the credit risk. Illinois's anti-evasion rule turns on this phrase.18

Control

Who designs, approves and funds

The California court weighed who originated, funded with its own capital, controlled underwriting, kept an interest and oversaw the program.17

Totality

Structured to evade?

Minnesota treats a party as the lender if "the totality of the circumstances" shows a structure built to evade its rules.19

The California case, and why it is still open

California's regulator argued that OppFi, the program manager, was the true lender of loans above California's limits that its partner FinWise Bank originated. On May 19, 2026 the Los Angeles County Superior Court disagreed: the bank originated the loans, funded them with its own capital, controlled underwriting, kept an interest and oversaw the program, so "the loans were lawfully made by an FDIC-insured state bank." The regulator filed its notice of appeal on July 21, 2026.17 A research answer on a partnership program in California should say the trial-court ruling is on appeal.

Valid-when-made is a different question. The OCC and FDIC rules say interest permissible when a bank made the loan stays permissible after the bank sells it.2,13 They help a buyer of a bank's loan. They do not decide who the lender was in the first place, which is the true-lender question.
08 · Small-business financing disclosures

Commercial financing disclosure laws by state: California, New York and the ten states that followed

Status as of October 2026

In shortConsumer protection now reaches small-business financing in a dozen states. Most require a consumer-style disclosure of the cost, often as an annual rate, on offers below a dollar threshold, and some add registration. Each state draws the line at a different size and covers different products, so a lender to small businesses needs its own fifty-state table.

Twelve states will have a small-business financing disclosure law by mid-2027

States with a commercial financing disclosure law in force at each year end

22022
42023
82024
112025
112026
122027 (scheduled)

Source 39,40,41,42,43,44,45,46,47 · California and Virginia in 2022; Utah and New York in 2023; Florida, Georgia, Connecticut and Kansas in 2024; Missouri, Louisiana and Texas in 2025; Vermont from July 1, 2027. Missouri's start depends on its regulator's rules; Venable counts it among ten states in March 2026.

Show the numbers
Year endStates
20222
20234
20248
202511
202611
2027 (scheduled)12
StateOffers coveredNotes
California$500,000 or lessRules operative December 9, 202246; SB 362 requires the APR whenever another price or charge is quoted39. AB 2116, signed September 30, 2026, brings small-business financing, including merchant cash advances and factoring, under the state's lending license law: most of it from January 1, 202848
New York$2,500,000 or lessRegulation adopted February 1, 2023, with six months to comply43
UtahOver $1,000,000 exemptRegistration and disclosure from January 1, 2023; no APR44
FloridaOver $500,000 exemptDeals made on or after January 1, 2024; banks and providers with five or fewer deals in 12 months exempt45
Connecticut and KansasConnecticut $250,000 (sales-based); Kansas $500,000From July 1, 202442
Texas and LouisianaSales-based and revenue-based financingTexas HB 700 from September 2025, with no exemption for low-volume providers39; Louisiana HB 470 from August 1, 202540
VermontUnder $1,000,000Licensing and disclosure from July 1, 202741

Georgia, Missouri and Virginia complete Venable's list of ten states (March 2, 2026), and a New Jersey bill was pending.39 The laws sit outside federal consumer credit rules, so they are found only by reading each state's code.

Enforcement has started. In August 2026 California's regulator settled with an equipment lender that made 22 commercial loans between 2022 and 2025 without a license, left out the required disclosures, including "the total cost of financing expressed as an annualized rate," and charged more than the state constitution's 10% on 18 equipment loans: a $44,000 penalty, $2,500 in costs and about $88,959 in credits to borrowers. The company neither admitted nor denied the findings.49
09 · State enforcement after 2025

State regulators and attorneys general after the CFPB pulled back: new powers and what they enforce

Status as of October 2026

In shortIn May 2025 the CFPB withdrew its reading that states could enforce federal consumer finance law broadly, while saying state powers under other laws were untouched. States have their own laws and are adding to them: New York added "unfair" and "abusive" to its consumer protection law in 2025, Illinois licensed buy-now-pay-later lenders in 2026, and California extended its lending law to small-business financing.

On May 15, 2025 the CFPB rescinded its 2022 interpretive rule on states' power to enforce the Consumer Financial Protection Act, saying "it is not altering, limiting, or affecting the authority of States" to act under any separate provision of state or federal law.50 A Mayer Brown review that August found "We have not seen a dramatic increase in state actions to date," and noted "reports of former CFPB staff joining various state regulator and attorney general offices."51 The industry association AFSA counted six states that had used the federal law's state-enforcement tools.52

State-licensed mortgage companies made 61% of US mortgage originations in 2025
61%

US mortgage originations by state-licensed mortgage companies in 2025, $1.2 trillion

Source 53

Show the numbers
MeasureValue
US mortgage originations by state-licensed mortgage companies in 2025, $1.2 trillion61 of 100
The scale state supervisors cover

In 2025 "more than 34,700 companies held a state license, and another 7,500 companies held a federal registration" in the national licensing system, across 98 state-licensed nonbank financial activities.53

Laws states added in 2025 and 2026

StateChangeDate
New YorkFAIR Business Practices Act: General Business Law § 349 reaches "unfair" and "abusive" practices, enforced by the Attorney General, protecting businesses and nonprofits as well as individuals; restitution "including for out-of-state victims where appropriate"54Signed December 19, 2025; in force February 17, 2026, 60 days later
IllinoisBuy-now-pay-later licensing, ability-to-repay underwriting, disclosure and dispute rules55Signed June 25, 2026; compliance from January 1, 2028
CaliforniaLending license law extended to small-business financing of $500,000 or less48Signed September 30, 2026; from January 1, 2028
OregonDIDMCA opt-out for consumer finance loans15June 5, 2026

For a research team the point is volume: every new state law adds sections to read, effective dates to track and answers that depend on them.

10 · How answers go stale

How often state lending laws change, and the four ways a saved answer stops being true

In shortNo one publishes a count, so the honest answer is "often, and unevenly." A saved answer goes stale when its section is amended, when an indexed cap moves, when a court rules on whose law applies, or when guidance it leaned on is withdrawn. Keep every answer with its citations and an "as of" date, and know which answers rest on which sections.

Two fee sections, eight versions: Florida's and Texas's rules keep moving
  1. 2006Texas

    Small-loan default-charge rule adopted (7 TAC § 83.602).

  2. 2010Texas

    Rule amended.

  3. 2013Florida

    Consumer finance rate and fee section amended.

  4. 2014Texas

    Rule amended.

  5. 2018Florida

    Amended again.

  6. May 12, 2022Texas

    Latest amendment in force.

  7. 2022Florida

    Amended again.

  8. 2024Florida

    Latest amendment (ch. 2024-276).

Source 5,7

Show the numbers
WhenWhat
2006Texas
2010Texas
2013Florida
2014Texas
2018Florida
May 12, 2022Texas
2022Florida
2024Florida

Four ways an answer goes stale

HowExampleWhat to record with the answer
The section is amendedFlorida § 516.031: amended 2013, 2018, 2022 and 20245The section and the version read
An index movesCalifornia's 36% plus the federal funds rate; Washington's 12% or T-bill plus four points23,25The formula, the index value used and the month
A court rulesColorado's opt-out (Tenth Circuit), Oregon's (District of Oregon), California's true-lender appeal9,32,17The case, its status and the date checked
Guidance is withdrawnThe CFPB's 2022 state-enforcement rule, rescinded May 15, 202550Every guidance document the answer relies on

When a new rule applies to a loan

A change usually reaches loans made after its effective date, and the act says so. Colorado's opt-out applies to consumer credit "made or renewed on or after July 1, 2024."21 For state banks, the FDIC rule fixes permissible interest at the date the loan was made, unaffected by "a change in State law."13 An answer therefore needs two dates: the version of the law it read, and the loans it covers.

Keeping state-law answers current: what Fed examiners look for

A Federal Reserve examiner's guide to change management describes five steps: identify new or revised laws and products and their risks, name the people responsible, build an action plan that covers research, impact, systems, policies and training, track due dates and report to management, and test after the change goes live. It adds that "the institution remains responsible for ensuring that the output from vendor-provided systems" meets regulatory requirements.56 For a multistate lender, the first step depends on a list nobody keeps by default: which saved answers, policy clauses and contract templates cite which state sections.

11 · What a wrong answer costs

What a wrong state-law answer has cost lenders: refunds, penalties and loans a court will not enforce

In shortAn overcharge repeated on every loan in a state becomes a refund program, a penalty and sometimes an unenforceable loan. California's regulator alone ordered more than $5 million in penalties in three 2025–2026 cases about rates, fees or disclosures, plus refunds. The costs that are hardest to see are product decisions made on an answer that was already out of date.

Three California orders on rates, fees and disclosures, October 2025 to August 2026

Penalties, refunds and credits ordered, as reported

Penalty: unlicensed lending, interest above caps on loans under $5,000 (June 2026)plus refunds, amount not published$4M
Penalty: fees and interest above the indexed cap (October 2025)$1M
Refunds in the same case$218.7K
Credits: commercial loans above the 10% constitutional limit (August 2026)$89K
Penalty in the same case$44K

Source 57,23,49

Show the numbers
OrderAmount
Penalty: unlicensed lending, interest above caps on loans under $5,000 (June 2026)$4M
Penalty: fees and interest above the indexed cap (October 2025)$1M
Refunds in the same case$218.7K
Credits: commercial loans above the 10% constitutional limit (August 2026)$89K
Penalty in the same case$44K

The largest of the three, against Navitas Credit Corp. in June 2026, combined unlicensed lending and payments to unlicensed brokers with interest and fees above California's limits on loans under $5,000: a $4 million penalty, $78,000 in costs and refunds to the borrowers overcharged. The report we read does not say whether the company admitted the findings.57 The second was about exactly the arithmetic section 04 describes: fees and interest above the limits on loans of $2,500 to $10,000.23

Where the cost lands

On the loan

In Florida, a loan with a charge above what the chapter allows "is not enforceable in this state," and everyone who took part in it is subject to the chapter.6 Overcharges found by the lender must be refunded within 20 days of discovery.5

On the research

Two lawyers and their firm, who filed a brief citing cases a chatbot had invented, were fined $5,000 by a federal court in 2023. The court noted that lawyers properly get help from "databases such as Westlaw and LexisNexis"; the failure was in never checking what the tool said.58

$5.88/payment

what a "5%, minimum $15" late fee overcharges on a $182.40 payment where the cap is 5% of the installment, as under Texas's general consumer-loan rule.8

Our arithmetic on the rule text
0

public counts we found of how often in-house fifty-state answers are wrong. Measure yours by re-checking a sample against the current text.

As of October 2026
12 · AI and legal research

Using AI for state law research: hallucination rates, the 2026 supervisory view and the checks that matter

Status as of October 2026

In shortSoftware can read 51 codes in parallel and do the arithmetic, and it can also state a wrong rule with confidence. Independent studies found general chatbots wrong on most federal case-law questions and specialist legal tools wrong on 17% to 33% of queries. The useful test is whether every answer carries its passage, so a person can check it in seconds, and whether the tool says when the text does not settle the question.

Even legal research tools built on retrieval gave false answers on a sixth to a third of queries

Share of answers with a hallucination in two Stanford studies, 2024

General chatbot (Llama 2), federal case questions88%
General chatbot (GPT-4), federal case questions58%
Specialist legal research tools, high end33%
Specialist legal research tools, low end17%

Source 59,60 · Different question sets: the chatbot study asked verifiable questions about random federal cases; the tools study used legal research queries.

Show the numbers
ToolAnswers with a hallucination
General chatbot (Llama 2), federal case questions88%
General chatbot (GPT-4), federal case questions58%
Specialist legal research tools, high end33%
Specialist legal research tools, low end17%

The first study asked general models specific, checkable questions about federal court cases and found legal hallucinations "between 58% of the time with ChatGPT 4 and 88% with Llama 2."59 The second tested commercial legal research tools that retrieve sources before answering and found they "hallucinate between 17% and 33% of the time."60 Neither tested state lending statutes, which are less often discussed online than federal cases and change on their own schedules.

SR 26-2 and the state supervisors' 2026 AI framework

Model guidance leaves generative AI to you. SR 26-2, which replaced SR 11-7 on April 17, 2026, puts generative AI outside its scope and leaves the controls to each institution's own risk management.61
State examiners may ask. On September 16, 2026 the state supervisors' association released an AI Supervisory Framework that lets examiners request information about an institution's AI tools; "Each state agency will determine the extent to which this framework is incorporated into their supervisory programs."62

Five checks before relying on software for state-law answers

  • Every state answer carries the passage it comes from and the version date, one click away.
  • Amounts are quoted from the text, then worked out on the stated loan, with the arithmetic shown.
  • A second, independent read compares each answer with its passage and removes what the passage does not support.
  • Where the text is ambiguous, or two sections conflict, the tool says so and a person decides.
  • Whether a rule reaches the lender (sections 03, 06 and 07) stays with counsel.
13 · How teams do it today

How compliance teams answer fifty-state questions today: who is involved, the hand-offs and where a day goes

In shortA question passes from product to an analyst, from the analyst to counsel, and back to product, and its sources rarely travel with it. Most of the analyst's day goes to finding and reading 51 sections; the judgment at the end gets the least time. Teams mix a free regulator survey, paid surveys and alerts, outside counsel for hard questions, and their own spreadsheets.

Who handles a fifty-state question: analyst, counsel, product, licensing, CCO

CA

Compliance analyst

Scopes the question, finds and reads each state's section, works out the figures, builds the cited table, flags what is unclear.

Cares about: time for the states that need judgment.
IC

In-house counsel

Reviews the answer, decides whether a rule reaches the lender, signs exceptions to policy.

Cares about: a citation for every row.
PM

Product manager

Asks the question, turns the answer into a fee schedule, a contract and a system setting.

Cares about: one rule to implement, with its exceptions.
LM

Licensing manager

Keeps the state licenses and the exam calendar; needs to hear when a watched rule changes.

Cares about: what an examiner will check first.
CO

Chief compliance officer

Owns the compliance program, the policies and the outside-counsel budget.

Cares about: evidence that answers are current.

From product's question to a signed state-by-state table

A fifty-state question changes hands four times before product can act
  1. 1Asked

    A message from product, collections or licensing.

    Product managerMinutes
  2. 2Scoped

    Product, loan size, charter, states in scope.

    Compliance analystAn hour
  3. 3Researched

    51 sections found, read, worked out, checked for changes.

    Compliance analystMost of a day
  4. 4Tabulated

    A cited table, ambiguities flagged.

    Compliance analystAn hour
  5. 5Reviewed

    Rows queried, sources re-found, exceptions signed.

    In-house counselHours to days
  6. 6Implemented

    Fee schedule, contracts, system settings.

    Product managerBy release

Illustrative · replace with your own numbers · Times are illustrative; no public source measures them.

Show the numbers
StepWhat happensWhoTime
AskedA message from product, collections or licensing.Product managerMinutes
ScopedProduct, loan size, charter, states in scope.Compliance analystAn hour
Researched51 sections found, read, worked out, checked for changes.Compliance analystMost of a day
TabulatedA cited table, ambiguities flagged.Compliance analystAn hour
ReviewedRows queried, sources re-found, exceptions signed.In-house counselHours to days
ImplementedFee schedule, contracts, system settings.Product managerBy release

Finding and reading 51 sections fill the analyst's day

Finding and reading sections take two-thirds of a fifty-state answer done by hand

Analyst hours for one 51-jurisdiction question, before counsel's review

Finding each state's controlling sectionReading it and working out the figureChecking for amendments and casesBuilding the cited tableChecking the company's own policy
By hand, about 7.5 hours3 hours2 hours1 hour1 hour

Illustrative · replace with your own numbers · An estimate; no public source measures time per fifty-state question. Time five of your own.

Show the numbers
Finding each state's controlling sectionReading it and working out the figureChecking for amendments and casesBuilding the cited tableChecking the company's own policy
By hand, about 7.5 hours3 hours2 hours1 hour1 hour0.5 hours

The people are skilled and well paid. Compliance officers earned a median of $38.81 an hour in 2025 and lawyers $76.76.63,64 Wages were 70.0% of private employers' compensation costs in June 2026, so a loaded hour is about $55 for a compliance officer and about $110 for a lawyer.65 Compliance costs weigh most on small institutions: in a St. Louis Fed study of 2014 data, banks under $100 million in assets spent 8.7% of noninterest expense on compliance, against 2.9% at banks of $1 billion to $10 billion, and personnel was "by far, the largest category."66

Free survey, paid charts, outside counsel, spreadsheets: where answers come from

Free

The regulators' survey

Verified by each state, broad, updated yearly. Leaves out payday, title and retail installment products.10

Paid

Surveys, charts and alerts

Publisher and law-firm fifty-state charts and alert services. Written for everyone, so they answer a general question, as of their last update.

Commissioned

Outside counsel

Right for novel or contested questions, where the lender is buying an opinion. Slow and costly for routine fee and notice questions.

The fourth is the team's own spreadsheets and email: fast to start, and the place answers lose their citations and dates.

Part B · See it working

Botminds State Lending Law Research: one late-fee question answered for 51 jurisdictions, cited and signed

Part A described the work without naming a product. This part shows how Botminds does it, at Larkhaven Financial, a fictional consumer lender licensed in all 50 states and DC. The people, the policy and the figures are sample data. The state rule text on these screens is the product's demonstration library, abbreviated; where it differs from the real law, the caption gives the real rule.

14 · One question, start to finish

Larkhaven's late-fee question: 51 jurisdictions answered in 41 seconds, 14 policy breaches found, one exception signed

In shortThis is the example from the top of the page, inside the product. Rachel Nwankpa, the senior compliance analyst, asks one question with the product's reference loan. State readers, one software agent per jurisdiction, answer in parallel, a checker reads each answer back against its passage, the company's fee policy is laid over the map, and the 14 jurisdictions where the policy breaks the cap come back as a drafted exception. Hannah Strandmark, associate general counsel, reviews and signs.

1

The question, with the loan it is about

Tuesday, October 13, 2026, 9:12 a.m. Tomás Reyes in product wants one late fee for the Flex Installment Loan. Rachel types the question in plain words. The facts come from the reference loan in Settings: a consumer installment loan, unsecured, $5,000 over 36 months, a payment of $182.40, rules in force on October 13, 2026.

She presses "Ask every state." The map fills as each state's reader finishes: 22 of 51 a moment later, then all 51.

Answering every state. The question and its loan facts above a US map that colors in as each jurisdiction's answer arrives.
2

How the answer was built, step by step

The research agent restated the question with its facts and scoped 51 jurisdictions. Fifty-one state readers read 214 candidate passages in parallel and worked out each cap on the $182.40 payment, applying "whichever is greater" or "less" as written. The citation checker read every answer back: 58 passages, 58 supported, none removed.

Change watch flagged three states as changed inside 90 days, and the policy gap agent laid clause 4.2 of the fee policy over the result. The last step is a person's: Rachel decides what to save and send.

How it was answered. Every step with its time, and the checker's count: 58 passages, 58 supported. The three "changes" are the demonstration library's sample events.
3

The answer on the map, every state cited

Fifty-one of 51 answered in 41 seconds, 58 passages cited. The map shades each state by its cap on the $182.40 payment: 8 at $10 or less, 6 from $10.01 to $14.99, 21 from $15 to $25, 9 above $25, and 7 with no fixed cap beyond the contract. These are the demonstration library's figures, so read them as a picture of the method.

Hover a state for the plain answer, the arithmetic and the citation.

The answer map. Every jurisdiction shaded by its cap, the answer in short, and the policy check: 14 jurisdictions where the fee policy is above the cap. Bands and counts come from the demonstration library.
4

Texas, opened to its passage

Rachel clicks Texas. The section opens as a page with the passage highlighted and, in the margin, the plain answer, the arithmetic, the citation checker's verdict and the policy check: the $15 minimum is above the Texas cap.

The real Texas answer for this loan is lower than the screen shows. The screen reads the small-loan rule, 7 Tex. Admin. Code § 83.602, which allows "5% or $10, whichever is greater." A $5,000 loan falls under the general consumer-loan rule instead, Tex. Fin. Code § 342.203(d): "five cents for each $1 of a scheduled installment," or $9.12 on this payment.8,7 The policy breaks the cap either way.

The cited section. The passage highlighted, the arithmetic and the checker's verdict beside it. The section text and the September 1, 2026 redline are the demonstration library's sample. The real § 83.602 governs small loans and was last amended effective May 12, 2022; for a $5,000 loan, § 342.203(d) caps the charge at $9.12 on $182.40.7,8
5

The policy laid over the answer, then signed

Clause 4.2 of Larkhaven's fee policy, CP-14, says "5% of the late installment, minimum $15." Laid over the map, it is above the cap in 14 jurisdictions. The policy gap agent drafts the fix: in those 14, the late charge is the lesser of the policy's amount and the most the state allows. It also notes that the $25 returned-payment fee in clause 4.4 is above the cap in 20 jurisdictions.

Rachel sends the draft to counsel. At 9:31 a.m., nineteen minutes after the question, Hannah Strandmark signs the exception with Schedule A attached.

The signed exception. The clause, the margin notes, the drafted "lesser of" text, counsel's signature and Schedule A with each state's cap and citation. Schedule A's caps are the demonstration library's.

The solution's design target is under one minute to answer a question for 51 jurisdictions, with every state answer cited to the section it comes from. Both are targets, to be measured on your own questions. In this run the signed exception came 19 minutes after the question was asked.

15 · Every screen

Nine more screens: the state-by-state table, a second question, the change feed and the team's saved answers

In shortThe map is one view of the answer. The same answer is a 51-row table to filter and export. A second question re-colors the same map. The change feed lists what moved on watched topics; the library keeps every saved answer with its review and marks it stale when a rule underneath changes; the rule library shows what is read and how fresh it is.

A state at a hover. The plain answer, the cap on $182.40 and the citation. The "changed last month" flag and the $10.00 are sample data; the real cap for this loan is $9.12.8
The policy over the map. One toggle outlines the 14 jurisdictions where the $15 minimum is above the cap, and a click opens a state's card with its quoted passage. The Pennsylvania wording and figure are the demonstration library's sample.
State by state. The same answer as a table: rule, cap on $182.40, days late, citation, change date and the policy check, filtered and exported with citations. The rules and citations are the demonstration library's; Texas's real cap for this loan is $9.12 under Tex. Fin. Code § 342.203(d).8
A second question, the same map. "What is the most we can charge for a returned payment?" re-colors the map: 53 passages, 34 seconds, and 20 jurisdictions where the $25 policy fee is above the cap (sample figures).
What changed. Changes on watched topics in the last 90 days, each with its redline and the saved answers and policies it touches. The entries shown are the demonstration's sample events; we found no such regulator actions.
Saved answers. 186 answers kept with their citations, who asked and for whom, counsel's review and reuse. Two are stale because a rule they cite changed.
The rule library. 25,909 sources kept by section and version: statutes, regulator guidance, enforcement orders, law-firm alerts and the company's own policies, refreshed nightly.
Your settings. The reference loan every cap is worked out on, the states in scope, the change window, who reviews, which policies are laid over answers and the topics watched.
Policy gaps, before review. Margin notes on clauses 4.2, 4.3 and 4.4 and the drafted exception, waiting to go to counsel.

Select any screen to open it larger. Larkhaven, the people, the policy and the figures are fictional; the state rule text is the product's abbreviated demonstration library.

In the case, the $15 minimum overshoots the cap by up to $10 a payment

How far Larkhaven's $15 minimum late fee sits above each of the 14 caps in its sample rule library, per late payment of $182.40

Massachusetts$10
New York, New Jersey, DC, Connecticut, Vermont, Maryland (each)$5.88
Texas (sample rule; $5.88 under the real rule)$5
Pennsylvania$4.06
Rhode Island$4
Maine, West Virginia (each)$3
Illinois$2.50
Minnesota$1.50

Fictional example from this guide · Figures from the demonstration library on the screens, except the Texas note, which uses Tex. Fin. Code § 342.203(d).

Show the numbers
JurisdictionAbove the cap by
Massachusetts$10
New York, New Jersey, DC, Connecticut, Vermont, Maryland (each)$5.88
Texas (sample rule; $5.88 under the real rule)$5
Pennsylvania$4.06
Rhode Island$4
Maine, West Virginia (each)$3
Illinois$2.50
Minnesota$1.50
16 · Agents, and who signs

Five agents read, check and draft; the analyst decides what is sent and counsel signs every exception

In shortEach agent has one job and limits it does not cross. None of them answers without a passage, edits a policy or sends anything outside compliance. The analyst decides what is saved and sent; counsel reviews every saved answer before it leaves compliance and signs any policy exception.

Research agent

Reads the question in plain words, fixes the loan facts it depends on (product, secured or not, amount, term, payment), scopes the jurisdictions and writes one plain answer per state from the readers' passages.

Never answers a state without a passage; outside the rule library it says so and stops.

State readers

One per jurisdiction, in parallel. Each reads its state's statutes, administrative code and regulator guidance for the facts asked, applies "whichever is greater" or "less" as written, and returns the passage, the section, the cap and the waiting period.

Never interprets beyond the text; ambiguity and conflicting sections go to a person.

Citation checker

Reads every plain answer back against its passage, the amount, the condition and the waiting period, and removes any sentence the passage does not support.

Never adds a source the readers did not use; every removal goes to the audit trail.

Change watch

Compares every cited section's version each night, flags changes inside the change window with a redline, and marks the saved answers and policy clauses that relied on the old text, telling their owners.

Never edits a saved answer; it marks it stale for a person to refresh.

Policy gap agent

Lays a linked policy over an answer clause by clause, lists the states where a clause breaks the rule and by how much, and drafts a per-state exception for counsel.

Never edits a policy document; it drafts, and counsel signs.

The analyst sends, counsel signs, the CCO owns the fee policy

Decides and sendsCompliance analystChooses what is saved to the library and what goes to product; routes unclear states to counsel.
Reviews and signsIn-house counselReviews every saved answer before it leaves compliance, decides whether a rule reaches the lender, signs policy exceptions.
Owns the programChief compliance officerOwns the policies laid over answers, the watched topics and the review rule.

Every question, its loan facts, every passage returned, the checker's verdicts and every review and signature are kept in the audit trail with who and when. Agent steps and human decisions are recorded separately.

Larkhaven's compliance, product and licensing team

Fictional, from the sample data
RN

Rachel Nwankpa · senior compliance analyst

Answers 30 to 40 state-law questions a week for product, collections and licensing.

"I can answer it for Texas in ten minutes. It's the other fifty that take two days."
TR

Tomás Reyes · product manager, personal loans

Launching the Flex Installment Loan in February 2027 with one fee schedule.

"I need one late fee I can print on every contract."
HS

Hannah Strandmark · associate general counsel

Reviews every answer before it goes in the library; signs policy exceptions.

"If it isn't cited to the section, it isn't an answer."
GW

Grace Whitaker · licensing manager

Owns 51 consumer lending licenses and their exam calendar.

"An exam starts with your policy and ends with the statute."
MD

Marcus Delgado · chief compliance officer

Owns the compliance program and the outside-counsel budget.

"We pay a firm thousands of dollars to tell us what a statute says."
17 · What goes in and out

Statutes, codes, guidance, orders and your own policies in; cited state-by-state answers and signed exceptions out

In shortIt reads the sources a compliance team already follows and the company's own policies, and leaves behind cited answers on a map and in a table, a library of reviewed answers that know when they are stale, and drafted policy exceptions for counsel. The systems of record stay where they are.

Law and guidance

  • State statutes and session laws, by section and version
  • Administrative codes and registers
  • Regulator bulletins, FAQs and guidance
  • Enforcement orders and settlements
  • The law-firm alerts the team subscribes to

From the company

  • Policies and procedures, by clause
  • Reference loans for each product
  • States in scope and the change window
  • Who reviews and who signs
Agents read every state, check and draft One question across every jurisdiction in scope, worked out on your reference loan
Counsel reviews before it leaves compliance
Every answer cited to its passage

Outputs

  • A cited answer for every state, on a map and in a table
  • The passage highlighted, with the version read
  • States changed inside the window, with redlines
  • A saved answer in the team library, reviewed by counsel
  • Policy gaps by state, with a drafted exception
  • An export with every citation

What changes for the team

  • Review cited answers instead of finding sections
  • Hear when a saved answer goes stale
  • Exceptions drafted, ready for counsel

Legal research, policy and pricing systems to connect

Legal research subscriptionsCodes, registers, surveys you license
Regulator and court sourcesBulletins, orders, dockets
Email alertsLaw-firm and association alerts
Policy managementPolicies and procedures by clause
Product and pricingFee schedules and reference loans
Document managementContracts and saved memos
Identity and accessWho reviews and who signs
Ticketing or GRCQuestions in, answers and exceptions out

For each, check whether it has an API, a file feed or only screens, who owns it, and what your license terms allow.

Cited, flagged when stale, signed by counsel: every state answer

1

No answer without its passage

Every state answer carries the section and version it comes from, one click away, for the analyst, counsel and an examiner.

2

Stale the morning a rule changes

A change to a cited section marks every answer and policy clause that relied on it, and tells their owners.

3

Agents draft; people sign

The analyst decides what is sent, counsel reviews it and signs exceptions, and nothing edits a policy on its own.

Part C · Are you ready to automate?

Automating fifty-state research: what wrong and slow answers cost, what software returns and how to test it

You answer state-law questions, manage the people who do, or rely on their answers. This part is written for you: where the costs sit today, what a research tool could return, whether your team is ready, what to ask any vendor of state-law research, including us, and how to test one on questions your counsel has already answered.

18 · What errors and delays cost

The cost of state-law research done by hand: analyst days, counsel hours and overcharges that become refunds

In shortStart from your own numbers. Nobody publishes how long a fifty-state question takes or how often in-house answers are wrong. What can be sourced is the price of the people and what regulators have ordered when a rate or fee was wrong. The biggest cost is the one that repeats: a fee charged above a cap on every loan in a state until someone reads the statute again.

$55/hr

a compliance officer's median wage, $38.81 an hour in 2025, loaded for benefits at the 70.0% wage share of employer costs. A lawyer's loaded hour is about $110.63,64,65

O*NET 2025 wages, BLS June 2026 compensation costs · our arithmetic
$4M

penalty in one June 2026 California order that also required refunds of interest charged above the state's caps on loans under $5,000.57

California regulator, as reported June 11, 2026
20 days

for a Florida consumer finance licensee to refund an overcharge after discovering it.5

Fla. Stat. § 516.031
Most of the hours in a fifty-state answer are finding and reading, which software can take

Analyst hours for one 51-jurisdiction question, before counsel's review

By hand (our estimate)With a research tool (illustrative)
Finding each controlling section3 hours0.1 hours
Reading and working out the figure2 hours0.1 hours
Checking amendments and cases1 hour0.1 hours
Building the cited table1 hour0.1 hours
Checking your own policy0.5 hours0.25 hours

Illustrative · replace with your own numbers · Neither column is a measurement. Time five of your own questions; measure the second column in a pilot.

Show the numbers
By hand (our estimate)With a research tool (illustrative)
Finding each controlling section3 hours0.1 hours
Reading and working out the figure2 hours0.1 hours
Checking amendments and cases1 hour0.1 hours
Building the cited table1 hour0.1 hours
Checking your own policy0.5 hours0.25 hours
What nobody publishes. There is no public figure for hours per fifty-state question, outside counsel's price per survey, the share of saved answers that are out of date, or how often a fee schedule carries a charge above a state cap. Vendor figures for these come without a dataset. Measure your own.

Pricing your own state-law questions: six costs and where they hide

CostWhere it hidesHow to find your number
Analyst timeFinding and reading sections, state by stateLog every multistate question for a month: who asked, hours spent, states covered
Counsel timeRe-finding sources to check rowsAsk counsel to log review minutes per answer for two weeks
Outside surveysInvoices for fifty-state work and alert servicesLast year's invoices, split routine from novel questions
Repeat researchThe same question answered again because nobody can find or trust the last answerSearch a quarter of email for repeated questions
Stale answersFee schedules and policies built on old textRe-check 20 saved answers against today's sections; count those that changed
OverchargesA fee or rate above a cap in one or two statesLay your fee schedule over each state's current cap; count states and affected loans

Refunds, forgone fees and exam evidence: costs outside the arithmetic

Refunds for every loan in a stateAn overcharge found late is repaid on every account it touched, often with a penalty on top.
The fee you never chargedWithout a trusted answer for each state, the strictest state's cap becomes the fee everywhere, and the lender gives up revenue where the law allows more.
A launch that waitsA product held for a week while fifty-one sections are read.
The exam that asks for evidence"Show us how you knew the rule changed" has no answer when answers live in email.
Knowledge that leaves with a personThe analyst who knew which states were tricky takes the list along.
19 · Your return

What faster, cited state-law answers return: analyst and counsel hours, fewer outside surveys, against the yearly cost

In shortPut in your own numbers. The calculator starts from published wages and asks you for the rest: how many fifty-state questions you answer, the hours they take now and after, counsel's review time, the outside surveys you buy, and what a tool costs a year. Every default marked illustrative is an assumption to replace.

Six ways cited state-law answers pay back

Analyst time

Review answers instead of finding them

Every state comes back with its passage and arithmetic; the analyst works the unclear ones.

questions × analyst hours saved × loaded hourly cost
Counsel time

Check a row by clicking it

Counsel opens the passage instead of asking where row 23 came from.

questions × counsel hours saved × counsel hourly cost
Outside spend

Routine surveys brought in house

Fee caps, waiting periods and notices answered internally; counsel kept for novel questions.

surveys a year × price × share brought in house
Accuracy

Fewer fees above a cap

Policies laid over every answer; gaps found before contracts print.

overcharges found early × loans affected × refund avoided
Currency

Stale answers flagged

A changed section marks every answer that rests on it.

saved answers re-checked by hand each year × hours each
Speed

Same-morning answers

Product gets a reviewed answer before the decision is made.

days from question to reviewed answer, before and after

Your analyst and counsel hours back on fifty-state questions

Only the hourly costs are built from published figures: O*NET's 2025 median wages for compliance officers ($38.81) and lawyers ($76.76), divided by the 70.0% wage share of employer costs.63,64,65 Every input marked illustrative is an assumption.

Your volume
Analyst time
Counsel time
Outside surveys and cost
Illustrative yearly value
Research and review time today, valued$0
Analyst time released, valued$0
Counsel time released, valued$0
Outside surveys avoided$0
After your yearly cost$0
Analyst hours released a year0
Questions a year to cover your cost from time alone0

Formulas, per year:
Time today = questions × (analyst hours × analyst cost + counsel hours × counsel cost)
Analyst time released = questions × (hours today − hours with a tool) × analyst cost
Counsel time released = questions × (review hours today − with a tool) × counsel cost
Surveys avoided = surveys × price × share brought in house
After your cost = the three values − yearly cost
Break-even questions = yearly cost ÷ (analyst and counsel value saved per question)

Count only the questions that needed an answer for every state. Not counted: refunds and penalties avoided, faster launches, stale answers caught, exam evidence. Released hours are value only when you decide what they are for.

Hours saved per question decide how many questions pay for a tool

Fifty-state questions a year to cover $60,000 of yearly cost from analyst and counsel time alone, at $55 and $110 an hour

Saves 6.5 analyst and 0.75 counsel hours a question136 questions
Saves 4 analyst and 0.5 counsel hours218 questions
Saves 2 analyst and 0.25 counsel hours436 questions

Illustrative · replace with your own numbers

Show the numbers
Hours savedQuestions a year
Saves 6.5 analyst and 0.75 counsel hours a question136 questions
Saves 4 analyst and 0.5 counsel hours218 questions
Saves 2 analyst and 0.25 counsel hours436 questions

A national consumer lender answering three or more fifty-state questions a week clears the first line. A lender in four states that asks a fifty-state question twice a year does not, and a free survey plus counsel may serve it better.

Start here20 · Readiness check

How ready your compliance team is to automate state-law research: volume, citations, policies and review

In shortPick the answer closest to your team today. Eight questions score 0 to 2; the last is for reflection. The meter adds up your score as you go, and each question says why it matters and what a strong answer sounds like.

1
Footprint

In how many states and DC do you lend, or plan to within a year?

Why it mattersThe work grows with every state: each one is another section to read for every question.
A strong answer"All 50 and DC for installment loans, and 30 for auto."
2
Question volume

How many multistate questions does your team answer in a month?

Why it mattersVolume turns hours per question into a budget line.
A strong answer"About 15 fifty-state questions a month, logged by who asked."
3
Citations

Do your saved answers carry the section, the version read and the date for every state?

Why it mattersWithout citations no tool can tell you which answers a change affects, and counsel re-checks everything.
A strong answer"Every answer in a shared folder, each row with its section and the date read."
4
Policies

Are your fee, collection and product policies written by clause, with state exceptions listed?

Why it mattersA policy can only be laid over a fifty-state answer if its clauses can be read one by one.
A strong answer"Our fee policy has numbered clauses and a schedule of state exceptions signed by counsel."
5
Change tracking

When a state amends a section, how do you find the answers and policies that relied on it?

Why it mattersSupervisors expect a process to identify changes and assess their impact, and the responsibility stays with you.56
A strong answer"We keep a list of cited sections per answer and check it against alerts monthly."
6
Findings

Have examiners, audit or a regulator raised a fee, rate or disclosure issue in the last three years?

Why it mattersFindings bring deadlines and budget. California alone ordered more than $5 million in penalties in three rate, fee and disclosure cases in 2025–2026.57,23,49
A strong answer"An exam found a late fee charged inside one state's waiting period."
7
Review

Is there a named counsel who reviews state-law answers before product relies on them?

Why it mattersA tool speeds research; a named reviewer keeps the answer accountable and decides whether a rule reaches the lender.
A strong answer"Our associate general counsel reviews every answer that leaves compliance."
8
AI governance

Do you have a way to approve AI tools: vendor review, a view on SR 26-2 and the state AI framework, and an audit trail?

Why it mattersThe 2026 model guidance leaves generative AI to your own controls, and state examiners may ask about your AI tools.61,62
A strong answer"Vendor management and model risk have a path for AI research tools, with human review on every output."
9
For reflection

If Colorado's case were decided tomorrow, how long would it take you to list every answer, policy clause and contract that depends on it?

Why it mattersYour answer shows whether your research is kept as citations or as conclusions.
A strong answerA short, specific list, for example: "every Colorado answer cites the opt-out statute and the case, and each has an owner who is told."

Next steps for a state-law research team at each score

0–6

Explore

Log a month of multistate questions, start citing the section and date on every answer, and write your fee policy by clause. Begin with one recurring question, such as late fees, kept as a reviewed table.

7–11

Ready to pilot

Test a tool on 20 to 30 questions your counsel has already answered and signed, then on live questions beside your team. Count agreements, disagreements and the minutes counsel spends checking.

12–16

Ready to implement

Plan the full set-up: sources and licenses, reference loans per product, policies laid over answers, the review rule, the library and change watch on every topic you track.

21 · Questions for any vendor

What to ask a state-law research vendor about citations, versions, the reach of a rule and your own policies

In shortAsk every vendor the same questions, us included. The answers show what the tool reads, how each answer is tied to its passage, how it handles a rule that does not reach you or a case still pending, and how you would measure it on your own questions.

AskA good answerA warning sign
What it reads
Which sources does it read for each state: statutes, administrative codes, registers, guidance, orders?A list by state, with how each is refreshed and what your licenses allow"The whole web" or a model's memory
Does it keep sections by version, and can an answer be read as of a past date?Yes; every answer shows the version date it readOnly the current text, with no history
How does it find the section that governs our loan when a state has several chapters?It asks for, or keeps, the product, charter, size and secured status, and shows why it chose the sectionOne answer per state, whatever the loan
Every answer, checked
Does every state answer carry its passage, one click away?Section, passage highlighted, version dateA confidence score in place of a passage
Who or what checks the answer against the passage?An independent read-back that removes unsupported sentences and logs it"Our model is very accurate"
What does it do when the text is unclear or two sections conflict?Says so, returns both, and routes it to a personAlways gives one confident answer
How does it show the arithmetic on our reference loan?The rule, the payment and the result, "greater" or "less" applied as writtenA number with no working
Reach and change
How does it handle rules that may not reach us: exportation, opt-outs, true-lender tests?Flags them, cites the federal text and pending cases, leaves the decision to counselDecides preemption on its own
How does it handle pending cases, such as Colorado's and Oregon's opt-outs?Marks the answer conditional, names the case and re-checks when it is decidedReads the statute as if no case existed
When a section changes, how do we learn which of our answers and policies it touches?The answers and clauses citing it are marked, and their owners toldA newsletter of changes
Your policies and review
Can it lay our own policy over an answer and list the states where a clause breaks the rule?Clause by clause, with the gap per state and a draft for counselEdits the policy itself
Can we require counsel review before an answer leaves compliance?Yes, as a setting, with the review on the recordAnyone can send any answer
Data, AI and proof
Which AI models do you use, where do they run, and does our data train them?Named models, a region you choose, no training on your data, in writing"Proprietary AI", no detail
Can we test it on questions our counsel has already answered, before we sign?Yes, blind, with every disagreement reviewedDemo questions only
What will you report from the test?Agreement by state and topic, wrong-section errors, unsupported sentences caught, counsel minutesOne accuracy percentage

Published tests found false answers in 17% to 33% of queries even in specialist legal research tools.60 A test on your own signed answers is the fairest comparison, and the same test measures your current process.

22 · A pilot on your own questions

Test a state-law research tool on questions your counsel already signed, then run it beside your team

In shortCollect questions your counsel has already answered and signed, run them blind, and score every state's answer against counsel's. Then run the tool beside your team on live questions for a few weeks. Decide on agreement, wrong-section errors and the minutes counsel spends checking.

  1. Log a month of questions with who asked, states covered and hours spent. That is your baseline.
  2. Collect 20 to 30 signed answers across fees, rates, notices and collection, including at least one where a rule did not reach you.
  3. Run them blind and score each state answer: agree, disagree, wrong section, unsupported sentence.
  4. Run beside the team on live questions for four weeks, with counsel reviewing both versions.
  5. Decide on three numbers: agreement by state, wrong-section errors, and counsel minutes per answer.
A ten-week pilot ends with a decision on three numbers
Your teamVendor
Log questions; collect signed answers
Load sources, reference loans and one policy
Answer the signed set blind
Score against counsel's answers
Run beside the team on live questions
Decide
Week 0246810

Illustrative · replace with your own numbers

Show the numbers
ActivityFromTo
Log questions; collect signed answers02
Load sources, reference loans and one policy13
Answer the signed set blind34
Score against counsel's answers45
Run beside the team on live questions59
Decide910

Scoring the pilot state by state, section by section

MeasureHowWhy
Agreement by stateState answers matching counsel's ÷ state answers, by topicOne percentage hides the states that are hard
Wrong-section errorsAnswers that read a section not governing the loanThe costliest error looks right on its face
Unsupported sentencesSentences the passage does not support, found by counselTests the read-back
Counsel minutesReview time per answer, both waysThe cost case rests on it
Changes caughtAmendments in the pilot weeks flagged against your saved answersShows whether answers stay true
The working-session questions: 18 questions in six groups

Bring compliance, legal, product, licensing, collections, vendor management and IT into one room. Each question says why it matters and what a strong answer and a warning sign look like.

A

Products, charters and states to cover first

A1

Which products, charters and states will the research cover first?

Why it mattersThe governing section depends on all three.
Strong answer · warning sign
A short list with reference loans.
"Everything, day one."
A2

Which questions stay with outside counsel?

Why it mattersNovel and contested questions need an opinion.
Strong answer · warning sign
Preemption, litigation, new products.
None; the tool decides.
A3

Who may ask, and who may see unreviewed answers?

Why it mattersUnreviewed answers leak into product decisions.
Strong answer · warning sign
Compliance asks; others see reviewed answers.
Open to all.
B

The codes, alerts and past answers you hold

B1

Which code and register subscriptions do we hold, and do their terms allow this use?

Why it mattersLicense terms limit what a tool may read.
Strong answer · warning sign
Checked with procurement.
Nobody has looked.
B2

Which alerts and guidance sources do we follow?

Why it mattersThey are early signals of change.
Strong answer · warning sign
A list, with owners.
Whatever lands in inboxes.
B3

Where are past answers, and can their citations be recovered?

Why it mattersThey seed the library and the pilot.
Strong answer · warning sign
One shared folder.
Personal email.
C

Fee policies, state exceptions and refund deadlines

C1

Which policies should be laid over answers first?

Why it mattersFee policies show gaps fastest.
Strong answer · warning sign
Fees, then collections.
None written by clause.
C2

Who signs state exceptions, and where are they kept?

Why it mattersExceptions are exam evidence.
Strong answer · warning sign
Counsel, in a schedule.
In email threads.
C3

When a gap is found, who fixes systems and contracts, and by when?

Why it mattersSome states set refund deadlines.5
Strong answer · warning sign
A named owner and a date.
"Next release."
D

Pending cases, change windows and stale answers

D1

What change window do we watch: 30 days, 90 days, a year?

Why it mattersIt sets what counts as "recently changed."
Strong answer · warning sign
Chosen per topic.
Not considered.
D2

Which pending cases and bills affect our answers today?

Why it mattersColorado and Oregon can change on a ruling.9,32
Strong answer · warning sign
A list with owners.
"We'll hear about it."
D3

Who is told when a saved answer goes stale?

Why it mattersA flag nobody reads changes nothing.
Strong answer · warning sign
The answer's owner and its users.
A shared inbox.
E

Approving an AI research tool and showing it to examiners

E1

How will model risk and vendor management treat an AI research tool?

Why it mattersSR 26-2 leaves generative AI to your own framework.61
Strong answer · warning sign
A known path and timeline.
First time anyone has asked.
E2

What will we show a state examiner who asks about the tool?

Why it mattersState examiners may request information on AI tools.62
Strong answer · warning sign
The audit trail and the pilot results.
The vendor's brochure.
E3

Who sponsors the change, and what budget moves?

Why it mattersA pilot without a sponsor ends as a demonstration.
Strong answer · warning sign
The CCO, with outside-counsel budget.
No sponsor.
F

If every fifty-state answer came back the same morning

F1

What if every product question got a cited fifty-state answer the same morning?

Why it mattersTests whether speed would change decisions.
Strong answer · warning sign
"We would stop setting fees at the strictest state."
"Product decides anyway."
F2

What if every policy clause showed the states where it breaks the rule today?

Why it mattersLinks research to policy and exams.
Strong answer · warning sign
Exceptions current, signed, dated.
Nobody would look.
F3

Which decisions would we never let software make?

Why it mattersTells you where the signatures belong.
Strong answer · warning sign
Preemption, exceptions, anything sent outside compliance.
"All of it": then start with finding sections.
23 · Frequently asked questions

State lending law questions answered: usury limits, 36% caps, late fees, DIDMCA opt-outs and true lender

In shortThe questions compliance teams and buyers search for most, each answered on its own, as of October 2026. The answers explain the law in general terms and are not legal advice.

What is state lending law research?

State lending law research is finding, reading and applying each state's rules for a lending question, such as the highest rate or late fee allowed, for every state where a lender operates. A good answer cites the section and version it comes from, works the rule out on the lender's actual loan, and notes anything pending that could change it. Counsel usually reviews it before a product team relies on it.

Which states have a 36% interest rate cap?

On the National Consumer Law Center's December 2025 chart for a $500 six-month loan, ten states sit at exactly 36%: Alaska, Connecticut, Illinois, Iowa, Montana, New Hampshire, North Dakota, Oregon, South Dakota and Wyoming. Ten more jurisdictions, including New York, Pennsylvania and DC, are lower, so 20 in all are at 36% or below. The list changes with loan size and with laws such as Illinois's 2021 all-in cap.

Which states have no usury limit on consumer installment loans?

On NCLC's December 2025 chart, Delaware and Missouri have no rate cap at all on the loans surveyed. Idaho, Utah and Wisconsin only prohibit unconscionable rates on a $500 loan, and a few more states do so for larger loans. A lender still faces other rules there, such as licensing and fee conditions.

Are banks exempt from state usury laws?

Largely, through federal law. A national bank may charge the rate its home state allows, including late fees, to borrowers in any state, and an FDIC-insured state bank has a similar power under DIDMCA section 521 unless the borrower's state has opted out. State-licensed nonbank lenders have no such power and must follow each borrower's state.

What is a DIDMCA opt-out, and which states have opted out?

Section 525 of the 1980 Depository Institutions Deregulation and Monetary Control Act lets a state declare that out-of-state state banks may not export their home-state rates on loans "made in" that state. Iowa has long opted out; Colorado did so from July 1, 2024 and Oregon from June 5, 2026. Colorado's enforcement against out-of-state state banks is blocked while the full Tenth Circuit decides the case, and Oregon's law is being challenged, as of October 31, 2026.

What did the Tenth Circuit decide about Colorado's opt-out?

A three-judge panel held 2–1 on November 10, 2025 that a loan is "made in" Colorado if either the lender or the borrower is located there, which would let Colorado apply its rate limits. On April 2, 2026 the full court vacated that decision and agreed to rehear the case, which restored the 2024 injunction blocking enforcement. Argument was set for August 18, 2026, and we found no decision as of October 31, 2026.

What is a true lender law?

A true lender law tells courts to look past the bank named on a loan to the company that really runs the program, often the one with the "predominant economic interest." If that company is the true lender, the borrower's state rate limits apply. Connecticut, Illinois, Maine, Minnesota, New Mexico and Washington are among the states that have written such tests into statute since 2021, and courts decide other cases on their facts.

How much can a lender charge for a late payment?

It depends on the state, the kind of loan and the payment. Florida allows up to $15 on a monthly consumer finance payment that is at least 12 days late, if agreed in writing; Texas's general consumer-loan rule allows five cents per dollar of the installment after the 10th day; Colorado caps the charge at $15 on loans not secured by land after ten days. Work each rule out on your own payment and check the waiting period.

Which states have commercial financing disclosure laws?

California, New York, Utah, Virginia, Florida, Georgia, Connecticut, Kansas, Missouri and Texas have some form of law requiring cost disclosures on small-business financing, Louisiana added one for revenue-based financing in 2025, and Vermont's starts July 1, 2027. Thresholds differ: California covers offers of $500,000 or less and New York $2,500,000 or less. California will also license small-business financing providers from 2028.

How often do state lending laws change?

No government or academic source counts it, so plan for continuous change. Single sections change every few years; Florida's consumer finance rate and fee section was amended in 2013, 2018, 2022 and 2024. Indexed caps such as California's 36% plus the federal funds rate move without any amendment, and pending cases can change whose law applies on the day they are decided.

Can states enforce consumer finance law now that the CFPB has pulled back?

Yes, under their own laws. In May 2025 the CFPB rescinded its broad reading of states' power to enforce the federal Consumer Financial Protection Act, while saying it was not limiting state authority under any separate law. States keep their own usury, licensing and unfair-practice laws, and some are expanding them, such as New York's 2025 FAIR Business Practices Act.

Is a 50-state survey of consumer finance laws free?

One is. The Conference of State Bank Supervisors publishes a 50-State Survey of Consumer Finance Laws, verified by each state's regulator and updated annually. It covers consumer loan licensing, mandated terms and fee limits, but leaves out payday, title and retail installment lending, so many lenders also need product-specific research.

Can AI do state law research accurately?

It can find sections and do the arithmetic quickly, but it must be checked. Stanford researchers found specialist legal research tools gave hallucinated answers on 17% to 33% of queries in 2024, and a federal court fined two lawyers and their firm $5,000 in 2023 for citing cases a chatbot invented. Use a tool that shows the passage behind every answer, read it back independently, and keep counsel's review.

24 · Summary and glossary

State lending law research on one page: the method, the October 2026 status and fourteen terms

Print this page

In shortThe whole guide on one screen: how to answer a fifty-state question, where the law stood on October 31, 2026, the readiness bands and the terms.

The method
  1. Fix the facts: product, charter, loan size, secured or not, the payment, the states in scope, the date.
  2. Place the lender: national bank, state bank, licensee or partnership; note opt-outs and true-lender rules.
  3. Find the section that governs this loan in each state, and read the exact words.
  4. Work the rule out on the payment: amount, form, waiting period, conditions.
  5. Cite the section and version; mark pending cases and indexed caps.
  6. Lay your own policy over the answer; draft exceptions for counsel to sign.
  7. Keep the answer with its citations, and re-check it when a cited section changes.

Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.

As of October 31, 2026: Colorado's opt-out enjoined, en banc decision pending · Oregon's opt-out in force since June 5, 2026, challenged · CFPB state-enforcement rule rescinded May 15, 2025 · New York FAIR Act in force · California AB 2116 from January 1, 2028 · SR 26-2 since April 17, 2026. Not legal advice.

14 terms
Usury limit
The highest interest rate a state's law allows, often several by lender and loan size.
APR, all-in
Annual percentage rate counting fees and charges with interest, as in the Military Lending Act method.
Rate exportation
A bank charging out-of-state borrowers its home state's rate.
DIDMCA § 521
The 1980 federal law giving insured state banks the export power (12 U.S.C. § 1831d).
Opt-out (§ 525)
A state's choice to make out-of-state state banks follow its rates on loans made there.
Preemption
Federal law displacing a state law that conflicts with it.
True lender
A test of who really makes a loan in a bank partnership, and so whose limits apply.
Valid when made
Interest lawful when a bank made the loan stays lawful after a sale.
Indexed cap
A cap tied to a market rate, such as 36% plus the federal funds rate.
Default or late charge
A fee for a payment made after a set number of days late.
UDAP / UDAAP
Unfair, deceptive (and abusive) acts or practices laws.
Commercial financing disclosure
A state rule requiring cost disclosures on small-business financing offers.
Reference loan
A fixed sample loan every state's rule is worked out on, so answers compare.
Stale answer
A saved answer whose cited section, index or case has changed since it was read.
25 · Sources

Sources

Accessed October 2026. Regulatory status statements are as of October 2026.

  1. National Consumer Law Center, "State Annual Percentage Rate (APR) Caps for $500, $2,000 and $10,000 Installment Loans", December 2025. nclc.org
  2. 12 CFR § 7.4001, Charging interest by national banks at rates permitted competing institutions, Legal Information Institute. law.cornell.edu
  3. ABA Banking Journal, "ABA files amicus urging full Tenth Circuit to hold Colorado's rate opt-out law violates DIDMCA", July 2026. bankingjournal.aba.com
  4. Ballard Spahr, Consumer Finance Monitor, "Plaintiffs tell Tenth Circuit en banc court that Colorado's opt-out law cannot reach loans made by out-of-state state-chartered banks", June 8, 2026. consumerfinancemonitor.com
  5. Florida Statutes § 516.031, Finance charge; maximum rates (Online Sunshine, 2026). leg.state.fl.us
  6. Florida Statutes § 516.02, Loans; interest; charges (Online Sunshine, 2026). leg.state.fl.us
  7. 7 Tex. Admin. Code § 83.602, Default Charges (amended effective May 12, 2022), Legal Information Institute. law.cornell.edu
  8. Texas Finance Code § 342.203, Additional interest for default, Texas Public Law. texas.public.law
  9. Orrick InfoBytes, "Tenth Circuit grants en banc review in Colorado DIDMCA opt-out case", April 3, 2026. infobytes.orrick.com
  10. Conference of State Bank Supervisors, "50-State Survey of Consumer Finance Laws" (verified by state regulators, updated annually). csbs.org
  11. Cantero v. Bank of America, N.A., 602 U.S. 205 (2024), Legal Information Institute. law.cornell.edu
  12. 12 U.S.C. § 1831d (DIDMCA § 521), with the statutory note on § 525 opt-outs, Legal Information Institute. law.cornell.edu
  13. 12 CFR § 331.4, Interest rate authority (FDIC), Legal Information Institute. law.cornell.edu
  14. Public Law 117-24, joint resolution disapproving the OCC rule "National Banks and Federal Savings Associations as Lenders", June 30, 2021, govinfo. govinfo.gov
  15. American Financial Services Association, "Defending Credit in Oregon", June 15, 2026. afsaonline.org
  16. L. Saunders, National Consumer Law Center, testimony in support of Rhode Island H 6055, April 24, 2025. nclc.org
  17. Ballard Spahr, Consumer Finance Monitor, "California DFPI appeals trial court decision rejecting its 'true lender' theory in OppFi case", July 31, 2026. consumerfinancemonitor.com
  18. Venable LLP, "Illinois Joins States Capping Consumer Loan Rates", April 22, 2021. venable.com
  19. Ballard Spahr, Consumer Finance Monitor, "Minnesota omnibus bill includes consumer loan law amendments for all-in APR cap and anti-evasion", July 24, 2023. consumerfinancemonitor.com
  20. Orrick InfoBytes, "New Mexico caps interest rates on small-dollar loans at 36%" (HB 132), March 4, 2022. infobytes.orrick.com
  21. Colorado General Assembly, HB23-1229, "Amending Terms Consumer Lending Laws" (signed June 5, 2023). leg.colorado.gov
  22. California Financial Code § 22304.5 (36% plus the Federal Funds Rate on loans of $2,500 to under $10,000), FindLaw, text current January 1, 2026. codes.findlaw.com
  23. Orrick InfoBytes, "DFPI fines firm $1M for allegedly overcharging borrowers", October 24, 2025. infobytes.orrick.com
  24. Federal Reserve Bank of St. Louis, FRED, Federal Funds Effective Rate (DFF), read October 31, 2026. fred.stlouisfed.org
  25. Revised Code of Washington 19.52.020, Highest rate permissible. app.leg.wa.gov
  26. Colorado Revised Statutes § 5-2-203, Delinquency charges, Colorado Public Law. colorado.public.law
  27. Texas Finance Code § 342.251, Maximum cash advance (Subchapter F), Texas Public Law. texas.public.law
  28. Texas Office of Consumer Credit Commissioner, Texas Credit Letter Vol. 45 No. 32, "Notice of Rate Bracket Adjustment", February 4, 2026 (§§ 342.251 and 342.259 ceilings $920 and $1,840 for loans made July 1, 2026 to June 30, 2027). occc.texas.gov
  29. Texas Finance Code § 342.502, Amount authorized (dishonored-payment fee by reference to Bus. & Com. Code § 3.506), Texas Public Law. texas.public.law
  30. Womble Bond Dickinson (Aspery, Savoie, Barringer), "New Year, Same Concerns: DIDMCA Opt-Out and True Lender Legislative Proposals to Watch", March 2, 2026. womblebonddickinson.com
  31. Orrick InfoBytes, "Oregon governor signs DIDMCA opt-out bill into law", April 10, 2026. infobytes.orrick.com
  32. Orrick InfoBytes, "Trade groups move for preliminary injunction in Oregon DIDMCA opt-out challenge", July 17, 2026. infobytes.orrick.com
  33. Congressional Research Service, "En Banc Tenth Circuit to Consider Scope of DIDMCA Opt-Out Provision", Legal Sidebar LSB11433, May 22, 2026 (EveryCRSReport copy). everycrsreport.com
  34. Ballard Spahr, Consumer Finance Monitor, "Twenty-one states file amicus brief supporting challenge to Colorado's effort to regulate interest rates charged by out-of-state state banks", June 9, 2026. consumerfinancemonitor.com
  35. L. Saunders, National Consumer Law Center, testimony in support of Rhode Island S-2206, April 14, 2026. nclc.org
  36. Connecticut Department of Banking, industry guidance on Public Act 23-126 (small loans, "true lender" in § 36a-556(d)), September 11, 2023; its notes cite 815 ILCS 123/15-5-15, 9-A M.R.S. § 2-702 and N.M. Stat. Ann. § 58-15-3. portal.ct.gov
  37. Maine Revised Statutes, Title 9-A § 2-702 (enacted by Public Law 2021, chapter 297), Maine Legislature, read October 31, 2026. legislature.maine.gov
  38. Washington State Legislature, House Bill Report on SSB 6025, "Protecting consumers from predatory loans" (Consumer Loan Act, chapter 31.04 RCW), 2024. leg.wa.gov
  39. Venable LLP, "State Commercial Financing Disclosure Laws: Recent Developments and Compliance Considerations", March 2, 2026. venable.com
  40. Mayer Brown, "Louisiana Now Requires Disclosures for Revenue-Based Financing Transactions", August 5, 2025. mayerbrown.com
  41. Mayer Brown, "Vermont Passes Commercial Financing Licensing Bill", July 8, 2026. mayerbrown.com
  42. Venable LLP, "New Commercial Financing Requirements Become Effective in Connecticut and Kansas", June 2024. venable.com
  43. Goodwin, "New York Finalizes Commercial Financing Disclosure Regulations", February 14, 2023. goodwinlaw.com
  44. Mayer Brown, "Utah Enacts Commercial Financing Disclosure Law with a Registration Obligation", March 30, 2022. mayerbrown.com
  45. Florida Statutes § 559.9612, Commercial Financing Disclosure Law, applicability and exemptions (Online Sunshine, 2026). leg.state.fl.us
  46. Cal. Code Regs. tit. 10, § 900, Commercial Financing Disclosures (operative December 9, 2022), Legal Information Institute. law.cornell.edu
  47. Code of Virginia § 6.2-2228, Sales-based financing, chapter 22.1 (2022, c. 516), Virginia Law. law.lis.virginia.gov
  48. Morrison Foerster, "California Expands the California Financing Law to Include Small Business Commercial Financing" (AB 2116), October 15, 2026. mofo.com
  49. Orrick InfoBytes, "California DFPI settles with company over unlicensed commercial lending and usury violations", August 21, 2026. infobytes.orrick.com
  50. CFPB, "Authority of States To Enforce the Consumer Financial Protection Act of 2010; Rescission", 90 FR 20565, May 15, 2025, govinfo. govinfo.gov
  51. C. Bieker, Mayer Brown, "Potential for Increased State Consumer Finance Enforcement", August 8, 2025. mayerbrown.com
  52. American Financial Services Association, "UDAAP: State Authority" issue brief, January 2025. afsaonline.org
  53. Conference of State Bank Supervisors, 2025 Annual Report, 2026. csbs.org
  54. Arnold & Porter, Enforcement Edge, "New York Enacts FAIR Business Practices Act", January 2026. arnoldporter.com
  55. Orrick InfoBytes, "Illinois enacts buy now, pay later licensing and consumer protection law", July 10, 2026. infobytes.orrick.com
  56. A. Burns, Federal Reserve Bank of Minneapolis, "Promoting Effective Change Management", Consumer Compliance Outlook, Second Issue 2019. consumercomplianceoutlook.org
  57. Sheppard Mullin (Dhaliwal and Madia), "DFPI Orders $4 Million Penalty for Alleged Unlicensed Lending Violations", National Law Review, June 11, 2026. natlawreview.com
  58. Mata v. Avianca, Inc., No. 22-cv-1461 (S.D.N.Y.), Opinion and Order on Sanctions, June 22, 2023. storage.courtlistener.com
  59. Dahl, Magesh, Suzgun and Ho, "Large Legal Fictions: Profiling Legal Hallucinations in Large Language Models", Journal of Legal Analysis 16(1), 2024. arxiv.org
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  61. Federal Reserve, SR 26-2, "Revised Guidance on Model Risk Management", April 17, 2026 (with OCC Bulletin 2026-13 and FDIC FIL-15-2026). federalreserve.gov
  62. Conference of State Bank Supervisors, "CSBS announces AI supervisory framework", September 16, 2026. csbs.org
  63. O*NET OnLine, Compliance Officers (13-1041.00), 2025 wages. onetonline.org
  64. O*NET OnLine, Lawyers (23-1011.00), 2025 wages. onetonline.org
  65. U.S. Bureau of Labor Statistics, "Employer Costs for Employee Compensation, June 2026", September 9, 2026 (copy on FRASER). fraser.stlouisfed.org
  66. Dahl, Meyer and Neely, "Scale Matters: Community Banks and Compliance Costs", Federal Reserve Bank of St. Louis, The Regional Economist, July 14, 2016. stlouisfed.org
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botminds.ai The complete guide to state lending law research · October 2026. Larkhaven Financial, every person, every policy and every figure in the example and the screens are fictional; the state rule text on the screens is abbreviated demonstration content. This guide explains the law in general terms; it is not legal advice. Regulatory and litigation status is as of October 31, 2026; check the sources and your counsel before relying on it.