The Commerce & Economic Development committee heard a one-day walkthrough of H.648, the Department of Financial Regulation (DFR) housekeeping bill, on Jan. 15, 2026. DFR staff described a mix of technical fixes and substantive changes affecting securities, banking and insurance statutes across Title 8.

DFR officials said the changes are largely editorial and harmonizing but include several policy adjustments meant to reflect Vermont’s market size and to clarify enforcement powers. "We're looking to decrease the de minimis exemption… from 25 purchasers down to 10," Amanda Smith, deputy commissioner for securities at the Department of Financial Regulation, told the committee, arguing the lower threshold is more appropriate for "Vermont's small market." She also said the bill would make clear that SEC Rule 506 offerings are not covered by the de minimis exemption and that firms offering sales in Vermont must file a Form D and pay an $820 notice fee within 15 calendar days of first sale.

The bill would codify several administrative penalty factors in 5604(e) to reflect existing practice and reduce exposure to jury-trial challenges after the 2024 U.S. Supreme Court decision in "SEC v. Jarkassee," Jennifer Root, assistant general counsel for DFR, told the committee. "We started looking at what would happen if this issue came up in Vermont… and we are seeking to conform the securities penalties to those [in Titles] 10 and 30," Root said, adding the change is meant to clarify that penalties are primarily equitable in nature and preserve administrative efficiency.

DFR also proposed edits to the Financial Services Education Victim Restitution Fund to clarify eligibility and confidentiality rules, defining dependent children by reference to the federal tax code, limiting awards to natural persons who were Vermont residents at the time of the violation, and clarifying that applications containing personally identifying information will be kept confidential. The agency added language on subrogation, forfeiture of awards for persons found to have engaged in fraud, and discretionary suspension or distribution of awards based on fund solvency.

On cybersecurity, DFR would add a statutory requirement for investment-advisory firms to maintain insurance sufficient to address the risk of a cybersecurity breach — a requirement DFR said already exists in its regulations and is being moved into statute for clarity.

Banking-focused changes led by Aaron Ference, deputy commissioner for the banking division, are mostly terminology and structure edits but include supervisory clarifications: converting many "registration" references to "license," strengthening prelicensure vetting and change-of-control review, and clarifying due-process routes for denials or revocations that can culminate in Washington County Superior Court. "We're essentially changing one term to another," Ference said of multiple edits, while noting some changes increase regulatory oversight of applicants and licensees.

Money-transmission provisions would expand and clarify definitions for money-transmission kiosks and virtual-currency kiosks, broaden the definition of kiosk operators to capture varied business models, and require display of the Vermont license number "on or at the location" of a kiosk so consumers can identify the responsible licensee. Ference said the changes are intended to capture business models where the party exchanging cash for virtual currency may not own the kiosk itself. He noted the moratorium on certain kiosk activity would otherwise expire June 30 without further legislation.

The bill also replaces inconsistent usages of "financial institution" with more specific terms such as "regulated entity" or "lending institution" across consumer-protection and banking statutes to reduce confusion about which entities are covered. DFR staff discussed interplay with federal preemption on lead-solicitation rules under the Fair Credit Reporting Act and said additional work may be needed to determine what states can regulate.

Committee members asked clarifying questions about specific statutory language, the breadth of prelicensure discretion, confidentiality of exam call reports, and how kiosk rules would affect business models. DFR staff frequently characterized many edits as clarifying or codifying existing practice.

No motions or votes were recorded in the transcript. The committee recessed for 15 minutes and planned to reconvene at 10:30 a.m. The DFR presenters said the securities sections are to take effect July 1 unless otherwise noted.

The committee is expected to continue review of H.648 in the same session; the transcript ends with a recess and no recorded formal action.