SB-908’s
Impact
Uncertain on
industry
By Jeffrey A. French, Esq.
On September 25, 2020, Governor Newsom signed Senate Bill 908 into law, enacting the Debt Collection Licensing Act (the “DCLA”). Its adoption places California with the majority of states that already require consumer debt collectors to be licensed. Notably, Senate Bill 908 (“SB-908”) is one of the three bills adopted pursuant to California’s three-part overhaul of the consumer financial services legislation. SB-908 came into effect on January 1, 2021, requiring the Commissioner of the Department of Financial Protection and Innovation (“DFPI”) to take all action necessary to implement the debt collection licensing requirements that became effective January 1, 2022. In order to meet the start date in 2022 for licensing, the Commissioner spent much of 2021 adopting regulations designed to implement the licensing program. Recognizing that there would be a flood of license applications in late 2021, any person or entity that submitted an application before the end of 2021 is permitted to operate in 2022 without the required license, and perhaps beyond, pending the approval or denial of the application by DFPI.
16 The Law Journal Summer 2022 | cacm.org
