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