AZ| The Arizona Department of Insurance and Financial Institutions (DIFI) Regulatory Bulletin 2025-04 provides guidance regarding consumer lenders who may also be engaging in sales finance activities in Arizona, particularly concerning loans connected to motor vehicles. The Bulletin clarifies regulatory requirements and the need for dual licensure under specific circumstances, outlines the Department’s interim position on enforcement, and invites industry feedback on potential solutions before enforcement begins in 2027.
Key Points:
- Dual License Requirement: Consumer lenders who are also involved in transactions that fall under the Arizona Motor Vehicle Time Sales Disclosure Act are required to obtain a separate sales finance company license if their activities exceed statutory thresholds.
- Temporary Non-Enforcement: The Department will not initiate enforcement actions or issue citations regarding these practices until January 1, 2027, allowing time for compliance and stakeholder input.
- Public Comment Period: Industry and interested parties are invited to submit written comments by September 26, 2025, to help formulate collaborative solutions and ensure consistent regulatory standards moving forward.