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CRL and NCLC Comment in Support of the DFPI’s proposal to Clarify that Fintech Cash Advances are Covered by the California Financing Law

May 17, 2023
Payday and Other Small Dollar Loans
Payday Loans
Comment Letter

The Center for Responsible Lending (CRL) and the National Consumer Law Center (NCLC) expressed support for the Department of Financial Protection and Innovation’s (DFPI) proposal to clarify that fintech cash advances are covered by the California Financing Law (CFL), including its fee and interest rate limits. The proposal requires that lenders be licensed under the CFL, with a temporary licensing exception for employer-based advances by firms that register under the California Consumer Financial Protection Law.