Consumers Affected
125
The Colorado Attorney General settled with Unlock Partnership Solutions, Inc., which marketed home equity agreements that were determined to be consumer credit transactions subject to Colorado's Uniform Consumer Credit Code and Consumer Equity Protection Act. The company must comply with lending laws, rate caps, disclosures, and licensing, and pay $283,375 in restitution to 125 consumers, with additional payments expected.
Unlock must comply with Colorado lending laws (UCCC and CEPA), including rate limits and disclosures, obtain required licenses, and pay restitution of $283,375 to 125 consumers, with additional payments as more loans close.
In-house legal teams should review vendor agreements with financial service providers offering home equity or alternative financing products. Key clauses to examine include: (1) compliance with state consumer lending laws (e.g., UCCC, CEPA), (2) interest rate caps and fee limitations, (3) disclosure obligations to consumers, (4) licensing requirements, and (5) indemnification for regulatory noncompliance. Additionally, customer-facing contracts should be audited to ensure they properly characterize transactions as credit or equity agreements and include required disclosures. Employee agreements related to sales or marketing of such products should also be reviewed for training and compliance obligations.
Entity
Unlock Partnership Solutions, Inc.
Industry
Financial ServicesOfficial Press Release
https://coag.gov/press-releases/unlock-partnership-solutions-agrees-to-comply-with-state-consumer-lending-laws-in-home-equity-agreements/
26.06.22 Unlock AOD fully executed
https://coag.gov/app/uploads/2026/06/26.06.22-Unlock-AOD-fully-executed.pdf
Colorado Attorney General Enforcement Page
https://coag.gov/
"Unlock Partnership Solutions, Inc."
"Unlock has identified $283,375 in restitution owed to 125 Colorado consumers"
"Colorado’s Uniform Consumer Credit Code"
"Colorado’s Consumer Equity Protection Act (CEPA)"
"the attorney general’s office determined that these agreements are consumer credit transactions under Colorado law and must comply with the Uniform Consumer Credit Code, including Colorado’s Consumer Equity Protection Act (CEPA), rate caps, required disclosures, and licensing obligations"
"Comply with Colorado lending laws under the UCCC, including the CEPA. Comply with UCCC rate limits. Provide disclosures required under the UCCC. Obtain all required Colorado licenses before resuming operations. Make restitution payments directly to consumers, with additional payments required as more loans close over time."
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