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AFSA Comments on CA Commercial Financing Disclosures

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AFSA’s State Government Affairs (SGA) team recently sent a letter to the California Department of Business Oversight (DBO)—now renamed the Department of Financial Protection and Innovation—to provide comments on the department’s recently proposed rules for commercial financing disclosures. The rules implement a law enacted by the legislature in 2018 that created significant new disclosure requirements for commercial accounts. Though AFSA members primarily offer consumer credit, our members also provide financing to commercial entities in the form of floorplan financing to auto dealers. The law largely exempts financing to auto dealers above certain amounts, so AFSA’s letter requested clear rules consistent with the exemption. AFSA also requested an amendment to the proposed rules clearly stating that certain contract clauses are not deemed as security interests and thus would not qualify as lease financing.

AFSA previously commented on the original legislation and previous versions of the proposed rules. Those previous comment letters and the most recent submission can be found on the SGA direct advocacy page.

AFSA Comments on CA Commercial Financing Disclosures
Oct 30, 2020

AFSA’s State Government Affairs (SGA) team recently sent a letter to the California Department of Business Oversight (DBO)—now renamed the Department of Financial Protection and Innovation—to provide comments on the department’s recently… Read the rest

AFSA Publishes Work From Home Model Legislation
Oct 29, 2020

AFSA’s State Government Affairs (SGA) team recently published model legislation that would permanently authorize employees of licensed entities to work from home without the need of a branch license. Since the start of the COVID-19 pandemic,… Read the rest

WATCH TODAY | Navigating the Road to Recovery
Oct 29, 2020

Join us on TODAY at 2:00 p.m. ET for Navigating the Road to Recovery: Proven Delinquency Risk Management Tools, presented by SWBC.

For auto finance companies, delinquency is a common challenge. Experts anticipate delinquency levels could… Read the rest

AFSA Responds to CFPB’s RFI on the CARD Act
Oct 28, 2020

This week, the American Financial Services Association (AFSA) commented on the Consumer Financial Protection Bureau’s (CFPB) request for information (RFI) on the economic impact of the Credit Card Accountability and Disclosure (CARD)… Read the rest

Double Up on Expertise: Conference Videos Now Available
Oct 26, 2020

The 2020 AFSA Annual Meeting & Independents Conference & Expo was packed with information and informative sessions. Did your kid run in during Cal Ripken’s session? Maybe the delivery guy showed up. Or maybe you just got sidetracked… Read the rest

AFSA Women’s Leadership Council Meet at AFSA Annual
Oct 19, 2020

The American Financial Services Association’s Women’s Leadership Council (WLC) kicked off its Fall meeting with Rochelle McClanahan, Chair, and Chief Financial Officer & Compliance Officer of Brundage Management / Sun Loan. Rochelle… Read the rest

AFSA Launches Women’s Forum
Oct 15, 2020

AFSA is pleased to announce that the Women’s Forum communities page is now live and ready for you to join! The Women’s Forum is a place to interact, network, and share best practices with other women in the consumer credit industry. All… Read the rest

AFSA’s Digital Library is Big … and Getting Bigger
Oct 13, 2020

AFSA’s first ever virtual conference, the 2020 AFSA Annual Meeting & Independents Conference & Expo, is in the books. From keynotes to breakouts to networking events, more than 500 attendees enjoyed the expertise that AFSA… Read the rest

2020 AFSA Annual Meeting & Independents Conference/Expo Recap
Oct 12, 2020

The 2020 Annual Meeting and Independents Conference & Expo opened on the sunny beaches of Aruba with a yoga session brought to us by Wells Fargo. Keynote speaker, Kristen Soltis Anderson, analyzed the 2020 political landscape and gave… Read the rest

AFSA SGA Whitepaper Covers Trends in Remote Work
Oct 02, 2020

AFSA’s October State Government Affairs white paper covers Trends in Remote Working. The white paper provides an overview of state regulatory guidance affecting remote work for financial services companies during the COVID-19… Read the rest

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