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ARTICLE · 30 MARCH 2023

California DFPI Proposes "Registration" Requirements

Manatt, Phelps & Phillips, LLP
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On March 17, the California Department of Financial Protection and Innovation (DFPI) proposed its long-awaited registration requirements for certain covered persons under the California Consumer...

United StatesFinance and Banking
Charles E. Washburn, Jr.
Charles E. Washburn, Jr.
Scott M. Pearson
Scott M. Pearson
Jan L. Owen
Jan L. Owen

On March 17, the California Department of Financial Protection and Innovation (DFPI) proposed its long-awaited registration requirements for certain covered persons under the California Consumer Financial Protection Law (CCFPL). The DFPI also proposed certain clarifying amendments to the California Financing Law (CFL) regarding advances. The text of the proposed regulations can be found here.

The CCFPL excludes from registration covered persons holding certain licenses, such as under the CFL, when acting within the scope of a license. The proposed regulations implement these exclusions by limiting registration to persons engaged in the following four businesses, each as defined in the regulations:

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