AFSA Urges Clarity on Debt Collection Act
AFSA’s State Government Affairs team recently submitted a comment letter on California’s Department of Financial Protection and Innovation Debt Collection Licensing Act. AFSA and the California Financial Services Association (CFSA) provided comments to the Department of Financial Protection and Innovation (DFPI) regarding the proposed scope rule under the Debt Collection Licensing Act. While appreciating steps toward clarification, we remain primarily concerned that the proposed regulation fails to properly address the role of indirect automobile financing in California.
We argue that indirect auto finance companies should be considered 1st Party Creditors under the exemption, aligning with federal law, and recommend using charged-off debt (instead of 90 days past due) as the trigger for certain requirements.
This letter, along with SGA’s other recent letters, can be found on the direct advocacy section of AFSA’s website.
December 18th, 2025
Get The News You Need
Sign up for our daily newsletter to receive all the most important industry news and updates every weekday morning.
Recent Posts
- CFPB Nom Moves On
- Rate Cap Still Being Proposed. Still Unhelpful to Consumers
- AFSA Supports CFPB Reform Bills
- 🚨THIS THURSDAY | AFSA Webinar | Beyond the Check: Modernizing Auto Refunds for Compliance, Cost and Customer Experience
- SGA’s Letter on Colorado Automated Decision-Making Technology Act