Proposed Narrowing of Licensing Exemption under California Finance Lenders Law

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The California Department of Business Oversight (“CDBO”) has proposed to narrow a long-standing interpretation of a statutory licensing exemption for certain lenders under the California Finance Lenders Law (“CFLL”)1. The interpretation applies the exemption to nonbank subsidiaries of banks and bank holding companies.

Section 22050(a) of the California Financial Code (“CFC”) provides an exemption for licensing under the CFLL for...

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