At an industry “listening session” on November 16, the California Department of Financial Protection and Innovation (DFPI) (formerly DBO) estimated a timeline for both the licensing requirement under the Debt Collectors Licensing Act (DLCA) and the registration requirement under the California Consumer Financial Protection Law (CCFPL). Both laws were enacted in the fall of 2020 and take effect January 1, 2021. For debt collectors, the DFPI indicated it would begin drafting regulations related to the licensing requirement starting in mid-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. The licensing requirement under the DCLA begins January 1, 2022. 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. The DFPI also confirmed that it would not expect debt collectors that obtain a license under the DCLA to also register under the CCFPL.
The DFPI also indicated it would draft regulations related to its new enforcement powers, but based on the focus of the call, it appears the DFPI will first emphasis the new licensing and registration requirements. The DFPI also indicated it would confirm and post these timelines to its website, but as of this post, the information could not be located.
For more information on this topic, including what persons and entities the requirements apply to, please see our previous blog posts about the CCFPL and the DCLA, or contact Laszlo Ladi at firstname.lastname@example.org