Our broad coalition of consumer and business organizations thanks you for the opportunity to comment regarding how the DFPI can best implement AB 1864 (Limón), the California Consumer Financial Protection Law (CCFPL). The CCFPL is an important and significant step forward for California and offers the promise of a bold consumer-facing department that can be at the forefront of consumer protection. We look forward to partnering with you and your team to help make that promise a reality.
We must first acknowledge that the on-going COVID-19 pandemic has exacerbated disparities for low and moderate income (LMI) households and communities of color, as it became very clear early on that this was not only a public health crisis, but an economic one, as well. Millions of individuals are facing unemployment, reduced income and heightened financial insecurity. The issues we are highlighting are brought to your attention by organizations that represent communities across California who have been historically harmed by the worst behavior from bad actors in the financial marketplace, and for whom DFPI can make a positive impact in their daily lives. We urge DFPI to take this opportunity to help even the playing field for individuals, families, and communities across the state.
DFPI, working with this unique coalition, has an opportunity to target thoughtful policy interventions to help get those struggling consumers to a better place than prior to the pandemic’s arrival a year ago. DFPI’s role in this work is extremely vital, and the formation into this new agency after passage of AB 1864 comes at a critical and opportune time. With that, here are the issues and recommendations that we’d like to bring to your attention. We should note that many of the groups signing onto this letter will also be providing more detailed comments under separate cover regarding some of these issues.