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On 31, 2020, the California legislature passed the California Consumer Financial Protection Law (CCFPL) august. What the law states reflects Governor Newsom’s eyesight of an infinitely more banking that is powerful with brand brand new enrollment authority, UDAAP authority mirroring the authority for the CFPB, and expanded enforcement authority. But crucial amendments used by the legislature will exempt many regulated entities through the range regarding the law and certainly will impose limitations regarding the Department that is new of Protection and Innovation’s (DFPI) workout of their authority.

We talk about the reorganization and expansion associated with banking regulator that accompanies the true title modification towards the DFPI within our companion client alert. We highlight the important thing conditions of this CCFPL below.

Concentrate on Customer Protection

Although all of the CCFPL comes straight from Dodd-Frank Act Title X, the statutory function varies through the function and objectives of Dodd-Frank. The legislative findings assert that “lack of [a dedicated economic solutions regulator with broad authority over providers of lending options and solutions] has left customers in danger of abuse and forced California organizations to compete with unscrupulous providers.”[1] They make reference to UDAAP also to discriminatory practices numerous times. They even make reference to technological innovation that “offers great promise,” but in addition “poses risks to consumer and challenges to police force.”[2]

On the other hand, the goals of Dodd-Frank Title X are a lot more balanced, talking about protecting customers from UDAAP and discrimination, but additionally: (a) the necessity for customers to possess prompt and information that is understandable make responsible decisions; (b) the requirement to reduce unwarranted regulatory burdens; (c) constant enforcement of federal customer economic legislation to market reasonable competition and transparency; and (d) efficient operation of areas for customer financial loans and solutions.[3]

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