News & Analysis as of

Banking Sector California

Allen Matkins

DFPI "Takes The Eleventh" In Suit Alleging Failure To Safeguard The Soundness Of First Republic Bank

Allen Matkins on

When an erstwhile shareholder of First Republic Bank sued the California Department of Financial Protection & Innovation for failing to safeguard the "financial soundness and structural integrity" of the bank, the DFPI "took...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 50: Navigating California’s Mortgage Landscape

Hosts Jerry Buckley and Sherry Safchuk sit down with Susan Milazzo, the CEO of the California Mortgage Bankers Association (CMBA), to discuss the current state and future of mortgage banking in California. As the voice of the...more

Allen Matkins

Will Your Industry Be On Deck For Registration With The California Department Of Financial Protection & Innovation?

Allen Matkins on

The California Consumer Financial Protection Law (CCFPL) authorizes the Department of Financial Protection & Innovation (DFPI) “regarding registration requirements applicable to a covered person engaged in the business of...more

Sheppard Mullin Richter & Hampton LLP

California Enacts Law Prohibiting State Banks and Credit Unions from Charging NSF Fees

On September 24, the Governor of California signed AB 2017 (the “Act”) into law. The Act prohibits state-chartered banks and credit unions from charging consumers non-sufficient fund fees (“NSF fees”) when they initiate...more

Orrick, Herrington & Sutcliffe LLP

California enacts bill on assessing license fees in deferred deposit transactions

On September 14, the Governor of California approved AB 3148 (the “Act”), amending the California Deferred Deposit Transaction Law (CDDTL) to change the formula for determining annual fee licenses as required to pay to the...more

Allen Matkins

California Court Upholds Daily Transaction Limits On Bitcoin ATMs

Allen Matkins on

A year ago, Governor Gavin Newsom signed two bills,  Assembly Bill 39 and Senate Bill 401, that created the California Digital Financial Assets Law.  SB 401 added Section 3902 to the Financial Code to prohibit an operator of...more

Allen Matkins

California Bill Would Deem Some Lenders As Licensed

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California generally requires that persons engaged in the business of making loans be licensed.  If not licensed under some other statute (such as the banking, credit union or residential mortgage lending laws), a lender will...more

Allen Matkins

California Bill Would Establish Registration Program With Respect To Commercial Financing Or Commercial Financing Brokerage...

Allen Matkins on

Recently, I wrote about the California Office of Administrative Law's rejection of regulations proposed by the Department of Financial Protection & Innovation.  These proposed regulations were intended to "implement,...more

Allen Matkins

Bank Runs And Social Media

Allen Matkins on

In this post from 14 years ago, I speculated as to whether California Financial Code Section 1327 was constitutional.  Two years later, the California Court of Appeal declared the statute unconstitutional.   Summit Bank v....more

Allen Matkins

DFPI Issues 2023 CCFPL Report

Allen Matkins on

Last week the California Department of Financial Protection & Innovation issued a report of its activities under the California Consumer Financial Protection Law.   The California legislature enacted the CCFPL in 2020 for the...more

Sheppard Mullin Richter & Hampton LLP

California AG Warns State-Chartered Banks and Credit Unions on Fees

On February 22, California Attorney General Rob Bonta sent letters to 197 state-charted banks and credit unions warning them that certain fees they charge may constitute “unfair” business practices under California’s Unfair...more

Sheppard Mullin Richter & Hampton LLP

California Bill Proposes to License All Commercial Loan Brokers

California has recently proposed legislation that, if enacted, would impose a new licensing requirement for any person providing “commercial brokerage” services to a borrower in connection with a commercial loan of $5,000 or...more

Perkins Coie

California DFPI Orders Consumer Financing Platform To Cease Hidden Junk Fees

Perkins Coie on

On January 9, the California Department of Financial Protection and Innovation (DFPI) issued an order against a consumer financing platform that enables merchants to offer installment contracts to their customers. The...more

Allen Matkins

Court Ruling Deals Blow To DFPI's "True Lender" Theory

Allen Matkins on

While the California Financing Law defines "finance lender", it does so in a very open-ended and nonspecific manner.  Cal. Fin. Code § 22009 ("'Finance lender' includes any person who is engaged in the business of making...more

White & Case LLP

Tying deposit insurance reform to reform of the tying of deposits

White & Case LLP on

On March 10, 2023 the California Department of Financial Protection and Innovation ("CDFPI") closed Silicon Valley Bank ("SVB"), a California chartered, non-member bank. The CDFPI placed SVB into receivership and appointed...more

Allen Matkins

Will New DFPI Lending Rules Reduce The Availability And Raise The Cost Of Small Business Loans In California?

Allen Matkins on

Three years ago, Governor Newsom signed AB 1864 into law.  This legislation gave the Department of Financial Protection & Innovation the authority to define unfair, deceptive, and abusive acts and practices in connection with...more

Orrick, Herrington & Sutcliffe LLP

DFPI, Fed to oversee bank’s self-liquidation

On June 1, the California Department of Financial Protection and Innovation (DFPI) announced that it issued a joint cease-and-desist order with the Federal Reserve Board to fulfill the voluntary liquidation of a...more

Allen Matkins

SEC Files Desist & Refrain Order Against Coinbase Alleging Failure To Qualify Staking Rewards Program

Allen Matkins on

Yesterday, the California Department of Financial Protection & Innovation announced that it had issued a desist and refrain order against Coinbase, Inc. The order alleges that Coinbase's staking rewards program involved the...more

Allen Matkins

DFPI Issues Self-Assessment Of Its Oversight And Regulation of Silicon Valley Bank

Allen Matkins on

Yesterday, the California Department of Financial Protection & Innovation published a 74-page report on its oversight and regulation of Silicon Valley Bank.  As explained in this earlier post, the bank was a state chartered...more

Allen Matkins

Will California's Bank Failures May Shine A Spotlight On California Corporate Law?

Allen Matkins on

As has been widely reported, the California Department of Financial Protection & Innovation announced that it has taken possession of another California chartered bank - First Republic Bank.  This is the second California...more

Orrick, Herrington & Sutcliffe LLP

DFPI cracks down on crypto platforms’ AI claims

On April 19, the California Department of Financial Protection and Innovation (DFPI) announced enforcement actions against five separate entities and an individual for allegedly offering and selling unqualified securities and...more

Orrick, Herrington & Sutcliffe LLP

FDIC announces California and Tennessee disaster relief

On April 13, the FDIC issued FIL-15-2023 to provide regulatory relief to financial institutions and help facilitate recovery in areas of California affected by severe winter storms, straight-line winds, flooding, landslides,...more

Allen Matkins

California's Commercial Loan Disclosure Requirements May Be Unconstitutional And/Or Preempted

Allen Matkins on

I have devoted several posts to a California commercial loan disclosure law that was enacted in 2018 - SB 1235 (Glazer).  Although the bill became effective on January 1, 2019, lenders were not obligated to comply until the...more

Allen Matkins

First A Failed Bank, Now A Spoofed Bank

Allen Matkins on

The closure of Silicon Valley Bank has understandably attracted a lot of attention.  There are, however, other ways to lose money when banking.  The California Department of Financial Protection & Innovation recently issued...more

Allen Matkins

What Was The DFPI's Role In Failure Of Silicon Valley Bank?

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Silicon Valley Bank was chartered by the State of California and was subject to the supervision of the California Department of Financial Protection & Innovation.  The DFPI was not the bank's regulator.  The bank had adopted...more

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