Equipment Leasing and Finance Association - Equiping Business for Success

ELFA Submits Comments Regarding California SB 1235

Posted 09/10/2019

ELFA Submits Second Round of Comments in Response to the Release of DBO Draft Regulations for SB 1235 (Financial Disclosure)

On July 26, 2019 the California Department of Business Oversight announced their completed review of initial comments and produced draft regulations as required by SB 1235.  ELFA submitted our original comments on January 21, 2019.  On July 26, 2019 the DBO, following the review of all initial comments, invited all parties to submit second comments addressing their draft regulations and sample disclosures. ELFA, working closely with our ELFA California DBO Member Workgroup, submitted our second and most recent comments on September 9, 2019. 

Important Reminder - SB 1235 Compliance is Delayed While the DBO Solicits Comments    

An important reminder to all ELFA members, as we alerted you in the past. ELFA has been informed by the DBO that compliance with SB 1235 will not be required through 2019 while the DBO receives comments, drafts regulations and promulgates rules, and compliance will then only be required after final regulations become effective. 

The DBO follows a comprehensive set of requirements that include pre-text and post-text comment periods, and when complete, the formal text will be submitted to the Office of Administrative Law for their approval. The legislation will not become effective until the quarter following their approval.

Read the Invitation for Comments notice on California DBO’s website.

For more information, please visit the ELFA State Advocacy - Lenders License page.

Amy Vogt
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