The California Department of Business Oversight (DBO) has finally released a much-anticipated draft rulemaking relating to the scope of the “agent of a payee” exemption under the California Money Transmission Act. The DBO’s rulemaking appears to affirm a broader interpretation of the scope of the exemption than has been historically applied, albeit with a number… Read More
In two recent actions, the California Department of Business Oversight (DBO) addressed whether companies that purchase retail installment contracts should be considered bona fide purchasers of credit sales or whether those transactions should be considered loans subject to the California Financing Law (CFL). In doing so, the DBO reiterates existing case law and sets forth… Read More
The California Department of Business Oversight (DBO) has issued a Release that summarizes the provisions of California Assembly Bill 539 and addresses some implementation issues. This bill was chaptered as Chapter 708 of the 2019 Statutes and is effective January 1, 2020. Our earlier Client Alert discussed the new law in detail. Read our client alert.
On July 26, the California Department of Business Oversight (DBO) issued a draft regulation and draft disclosures to implement the state’s first-of-its-kind commercial financing disclosure law enacted last year. With this draft regulation, the DBO wades into uncharted waters in implementing the first law requiring disclosures of key terms in connection with certain commercial financings by non-banks. Read our client… Read More
The California Department of Business Oversight (“DBO”) has issued an Invitation for Comments relating to the scope of the “agent of a payee” exemption under the Money Transmission Act, Cal. Fin. Code § 2000 et seq. Comments are due on April 9. According to the DBO, it is seeking comments because it intends to develop… Read More