A license is not the only thing one needs. One needs to believe one is operating within the rules set by each state. Each state has lots of borrower protection rules. A change in interpretation of one of these rules by the corporate lawyers could easily trigger this. Could be as subtle as a perceived risk that some regulator might later interpret something as not being in compliance with some rule. Could be triggered by a change in a rule, or a particular court case which gave some color to some rule, or a new lawyer bringing a new point-of-view about interpreting a rule. Very difficult to diagnose from a distance.