AZ DFI Regulatory Bulletin 2021-01: Collection Agency Licenses: Branches

• A.RS. § 6-855(A) requires an application and fee for a trust company branch. • A.RS.§ 6-705 requires a debt management company to apply for branch licenses. • A.RS. 44-282(G) requires a sales finance company to obtain a license for each separate place of business (branch). Moreover, the practical policy considerations for requiring separate branch licenses as it relates to these examples are not the same for collection agencies. Escrow agents, consumer lenders, mortgage bankers, trust companies, debt management companies, and sales finance companies frequently operate offices at different locations where customers may visit to obtain financial services products and assistance. The Department may find that operations at a particular branch location do not comply with Arizona law and may take action against the parent license and the branch license, or even just the branch license depending on the circumstances. Collection agencies generally are not similarly situated, particularly because customers are not visiting collection agencies to obtain services in the same way as the other mentioned licensees. Please direct any questions related to this Regulatory Bulletin to Steven Fromholtz at (602) 364- 4455 or steven.fromholtz@difi.az.gov. 2