November 05, 2024

California DFPI's New Requirements for Debt Settlement, Education Finance, and Wage Access Providers

2 min

The California Department of Financial Protection and Innovation (DFPI) has implemented new registration requirements under the California Consumer Financial Protection Law (CCFPL), effective February 2025. For the first time, providers offering services in debt settlement, student debt relief, private postsecondary education financing, and income-based advances must register by February 15, 2025 with the DFPI to operate in California. These rules represent a significant regulatory shift, impacting operational standards, compliance, and reporting obligations.

New Registration Categories Under the DFPI Rule

The DFPI's new rule creates registration categories for financial service providers in:

  • Debt Settlement Services: Companies that negotiate or settle debts on behalf of consumers
  • Student Debt Relief Services: Providers assisting borrowers in managing or reducing student loan debt
  • Education Financing: Institutions and third parties offering credit for postsecondary education expenses
  • Income-Based Advances: Services commonly referred to as earned wage access, allowing early access to earned wages

Providers operating in these areas will now need to submit to a registration process that includes ongoing reporting and compliance measures. For many companies, this will mean increased regulatory obligations and additional administrative oversight.

DFPI Regulations: https://dfpi.ca.gov/california-consumer-financial-protection-law-regulations-legislation-opinions-and-releases/

DFPI Registration Info: https://dfpi.ca.gov/ccfpl-registration/

NMLS System and Registration Process

The DFPI is using the Nationwide Multistate Licensing System & Registry (NMLS) to manage registrations. Providers must file applications, amendments, and fees through the NMLS, streamlining compliance under a centralized system. The application process requires detailed information on business practices, including management structure, financial operations, and disclosures on services offered in California.

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