AFSA Comment Letter Expresses Concern on Nevada Law August 27, 2019 AFSA’s State Government Affairs team sent a letter to the Commissioner of the Nevada Financial Institutions Division on SB 311 as a follow up to an in-person meeting with the division on August 22nd. Effective October 1, SB 311 would require creditors to deem an applicant with no credit history to have identical credit history to a spouse’s or former spouse’s credit established during a marriage. While AFSA supports measures that responsibly expand consumers’ ability to access appropriate credit, AFSA expressed concern that provisions of SB 311 appear to be legally unworkable as both the federal Fair Credit Reporting Act (FCRA) and Equal Credit Opportunity Act (ECOA) preempt state law. In the letter, AFSA requested that the commissioner issue a notice of non-enforcement and seek an opinion from the Attorney General on the preemption issues raised by the law. AFSA’s SGA team is working closely with other trade associations in the state and the Nevada Financial Institutions Division to resolve this issue. You can view this letter, along with other comment letters at the direct advocacy section of SGA’s webpage.