CFPB Ca Style: The California Customer Financial Protection Law Brings More Prov Morrison & Foerster LLP
On August 31, 2020, the California legislature passed the California customer Financial Protection Law (CCFPL). What the law states reflects Governor NewsomвЂ™s vision of an infinitely more powerful banking agency with brand new enrollment authority, UDAAP authority mirroring the authority regarding the CFPB, and expanded enforcement authority. But crucial amendments used because of the legislature will exempt many regulated entities through the range regarding the legislation and can impose limitations from the brand new Department of Financial Protection and InnovationвЂ™s (DFPI) workout of the authority.
We talk about the reorganization and expansion for the banking regulator that accompanies the title modification towards the DFPI within our companion client alert. We highlight the main element conditions regarding the CCFPL below.
Concentrate on Customer Protection
Although the majority of the CCFPL comes directly from Dodd-Frank Act Title X, the statutory function varies through the function and goals of Dodd-Frank. The legislative findings assert that вЂњlack of [a dedicated economic solutions regulator with broad authority over providers of lending options and solutions] has left customers susceptible to abuse and forced California organizations to compete with unscrupulous providers.вЂќ They make reference to UDAAP also to discriminatory methods times that are multiple. Additionally they make reference to technological innovation that вЂњoffers great promise,вЂќ but additionally вЂњposes risks to consumer and challenges to police force.вЂќ