The CCFPL provides the DFPI the exact same UDAAP authority that Dodd-Frank Title X provides the CFPB: The DFPI may take enforcement action against covered people for UDAAP violations and certainly will issue regulations regarding UDAAP.10
The CCFPL additionally allows the DFPI to bring proceedings pursuant towards the Dodd-Frank Title X provisions state that is authorizing to enforce Title X and any laws promulgated by the CFPB pursuant to Title X.11 The DFPI may bring these procedures against both covered persons under the CCFPL in addition to current DBO licensees, including California-licensed banking institutions, cost cost savings and loans and credit unions, California Financing Law licensees, and California household Lending Act licensees.
The DFPI will need to offer advance notice into the CFPB if it hinges on this authority to carry actions against existing licensees. There is absolutely no comparable requirement in the CCFPL for actions brought against covered persons which are not exempted.
The CCFPL authorizes the DFPI to recommend guidelines determining UDAAP, which will connect with covered persons. The DFPI must interpret вЂњunfairвЂќ and вЂњdeceptiveвЂќ in accordance with Business & Professions Code part 17200 and cases interpreting that supply. Weiterlesen