In July 2022, the California Department of Financial Institutions (DFPI) published proposed regulations that would impact licensing, reporting, and record retention. On August 29, 2022, the Consumer Relations Consortium (CRC) submitted comments to the DFPI to address the proposal's conflicts with other California laws, confusing definitions, and unreasonably burdensome requirements.
The CRC's comments were prepared by Legal Advisory Board (LAB) members Joann Needleman of Clark Hill, Brit Suttell of Barron and Newburger, along with Stefanie Jackman and Jonathan Floyd* of Troutman Pepper.
In its comments, the CRC asked the DFPI to modify its proposed regulations as follows:
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