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Ohio
In October 2025, Ohio's banking regulator walked back prior guidance under the Small Loan Act, easing its licensing position for bank partnerships. The reversal represents a significant shift in the state's approach to regulating bank-fintech lending partnerships, reducing licensing burdens for banks and their fintech partners operating in Ohio. This action demonstrates the evolving and sometimes contradictory nature of state-level regulation of BaaS partnerships. The guidance change may facilitate bank-fintech lending partnerships that had previously faced uncertainty under Ohio's prior, more restrictive interpretation of the Small Loan Act.
Verified from source: As of October 31, 2025, the Ohio Division of Financial Institutions updated its guidance on the application of the Small Loan Act to bank partnerships, reversing its earlier position and stating it will not require non-bank entities compensated for arranging bank loans to obtain an SLA license, and will not pursue enforcement for 2025 activity without a license.
- State-level regulatory guidance on BaaS partnerships remains fluid, creating both opportunities and uncertainty
- Eased licensing requirements could encourage more bank-fintech lending partnerships in Ohio
- Other states may follow Ohio's example in revisiting restrictive partnership licensing requirements