During a telephone conference call on December 8 labeled as a “listening session,” California’s newly renamed DFPI (formerly DBO) provided additional details about its upcoming plans for rulemaking related to the California Consumer Financial Protection Law (AB 1864, aka the mini-CFPB) and related to the Debt Collectors License Act (SB 908).

Similar to what was discussed during the first such listening session, the DFPI indicated it would begin drafting regulations related to the licensing requirement in the DCLA starting in the first quarter of 2021, and open a window for debt collectors that are covered by the new licensing requirement to apply for a license starting in the summer or fall of 2021. For newly covered persons under the CCFPL, again, the DFPI indicated it would begin drafting regulations related to the registration requirement in mid-2021. However, the DPFI indicated it did not expect the registration process for newly covered persons to open until early 2023. In addition to the licensing and registration requirement, the DFPI indicated it would begin drafting a second “package” of rulemaking in 2021 related to enforcement.

During the listening session call, the DFPI also encouraged participants and stakeholders to provide feedback and questions and indicated these comments may inform the DFPI’s drafting of rules and regulations. The DFPI indicated it may hold a third such listening session in early 2021 as well. For the CCFPL, the DFPI also clarified it would open one or more “Invitations for [written] Comments”, likely in early 2021, prior to commencing the official rulemaking process with the Office of Administrative Law or OAL.

Finally, the DFPI provided these timelines and plans for rulemaking on a webpage and indicated that page would be periodically updated with new information.

For more information please contact Laszlo Ladi at ll@severson.com.