[Karen37a]

Karen, what did I say that was negative? I just pointed out that you keep saying the same thing over and over, which if you go through this thread you have. Not negative true. And you can call me anything you want because I truly dont care.

Kevin I completely agree with your statement. Getting in front of this adapting and changing is the key to survival and ultimately being successful

You are constantly saying things you dont like me. Ignore me.

I am not here to solve your dilemma ... non-sales. When some of you had a chance to do something you didn't, Now it isn't going to work out for you...and i can take the over under on that

[Karen37a]

this bill is a done deal and is going to pass. Unfortunately other states now have something they can use as a model and this is where we as an idustry can get screwed.. California has always been a harder state to get deals done in because a lot of companies require a lending license, thesn't kill us.is bill passing will not have a huge affect on the industry. Where we will have a problem is if this bill becomes the model for other states to use for their own regulation. This is why it is important to have a voice in the room fighting so that any legislation that does pass in terms of regulation do. Anyone who thinks there wont be more bills like this in the future in other states is kidding themselves.

This is why it is important to have a voice in the room fighting so that any legislation that does pass in terms of regulation do

there were three major voices who went to the legislation to give their opinions

1) That I have been disagreeing with from the start

2) I was neutral on

3) I don't like their rates but side with them ( because I do not want regulation)


the # 1 created this and thought it would knock D paper out...and we do not have to see me repeat myself again...I said it wouldn't just knock D paper out


So what are you supposed to do when all sides don't agree? Type word salad like I did because they can see this.

Unfortunately what I have found on wall st is the ones who are really book smart...have no street smarts, And for some reason cannot see the negative consequences until after the fact. The too street smart ones do not give a crap ...and the people in the middle suffer


Everyone have a great weekend and Happy Rosh Hashanah to those who celebrate

[Karen37a]

merchant's who need the money, even if disclosed, will still sign to get the money. Will some merchant's jump out of their seat if an APR is disclosed on front page of contract? Yes. Time will tell how this shapes the industry in Cali and if other states adopt the practice in the future

Articles on unconscionability

https://www.sfchronicle.com/bayarea/...e-13153780.php

https://www.americanbanker.com/news/...lif-high-court

__

Calif. Supreme Court: High-Interest Loans May Be Subject to Price Unconscionability Attack ( this was a consumer payday loan)

I still believe ( I am not a lawyer) "plaintiffs have the burden of proof an and will have to prove that the lender" operated in a noncompetitive market or charged interest at rates that departed significantly from rates charged by competitors," and whether the rates were excessive in relation to costs and/or generated excessive profits"

And this is where the bice comes in...best pricing

Some Lenders like pp are at 9% ?

You add Fiduciary into this mix anyone who doesn't meet or beat that rate will be in breach of Fiduciary Duty

** And I am repeating myself again...there are going to be lawsuits set up just so merchants can weasel out and debt relief is going to go on the attack( this is the major reason for me not getting a Calif Licence and past posts have me stating" you are going to get sued" )

And numerous people wanted regulation...advocated for it, over and over and over me beating against it over and over and over...they wanted this and pushed for it


*** I can see one way to possibly protect against liability. I am going to check financial privacy laws before I toss the solution out ***...and repeating I am not a lawyer so the idea will have to be checked


__
As I sit here thinking about all this like bad dream some people should realize that some of us have squeaky clean ex-licences because we try to know the laws and rules, possibilities, landmines and traps. I said in the past its like I am watching people being herded like sheep into a fire pit from hell numerous time and that it is hard for me to stay silent watching it.
And disparaging my background to get a point across, then looking into it and then You found out I was in Igc ..big bang theory classes, 12th grade reading and math level n the 3rd grade, played the clarinet, was on a swim team at the YMCA , gymnastics team, tennis team, Ymca Leader club Vice president, youth and govt, volunteers for handicapped swim, and taught the underprivileged kids to swim, sat morning program coordinator 4 years from 9th grade to 12th ( taught kids gym, swimming and arts and crafts...every sat morning).. and was most popular in High school., aerobics instructor and a lifeguard, driving around in a red BMW convertible ..happy? Made you feel better or worse?)


I do not have a crystal ball to see things. In business, you live through things ...30 years of living through things in financial services.. I think I understand some of it. I know Regulation is a nightmare. I was not hiding from something crazy like he tries to make it seem so he can get his piker agenda through.

The overconfidence of some who think because they can say "vertical" 'box" and other industry jargon terms that makes them relevant in some way.
People use other peoples false ego against them to con them. Take their shoes right out from underneath them as they are saying "thank you for letting me call myself CEO on a business card because id never be 1099"...(great send me your deals..white label) (" you are 1099 you fool..Karen").

This is not a game anymore...I told everyone that months ago.

People need to regroup...i said NOW OR NEVER 100 times...this is really the last time I am helping

People in Calif should be pissed off

__

You have bled with Wallace now bleed with me

https://www.youtube.com/watch?v=eclbaC3q94k


Add Edit...I forgot that I played softball....pitcher and shortstop, over 400 batting average .. MVP ..went to the state regionals lost in the final game( they broke our team up said it was unfair, we were slaughtering people 40 -0)...they made rules to stop the games ..we would have won if they didnt break us up... and did ballet, tap and jazz dance

Some were predestined for wall st( from hard work up t 5 am before school to go to swim practice)...some a truck driver ( and there is nothing wrong with it but this is Finance)...we are a capitalistic society, not socialists...deal with it

Once we were broken up...my best friend hit a home run off of me to win a final game( the following year.)..i didnt know if I should hug her or cry...we did hug each other on the mound ...some of you people need to learn how to lose with dignity

[Karen37a]

On another bad note did anyone else hear that they are trying to make sure the Brokers /Isos are liquid 100k? Who were domiciled in Calif?

Like a net cap requirement to hold the licence and a bond?

Here is Finras Net Cap Requirement


https://www.finra.org/sites/default/...pretations.pdf


***regulated Finra investments and Regulated loans were my specialities and backyard

When was saying ...i was an osj, series 24...compliance etc ...that = regulation cop over the organizations....which is not my favourite position to be in

Called Super OSJ...like Super Isos Compliance or MasterGeneral Agent...compliance over thr general agents offices and their agents

Article on the benefits of transitioning to a Super Osj

https://www.practicebuildertools.com...mall-bd-to-osj


There is so much to know in regards to regulation of loans and investments...smh

# 1 thing. Someone who was in a compliance position for over 25 years in multiple states with multiple brokers with multiple products, without incident has no problem getting thru regulation.

[Karen37a]

Check the current exception list on the bill I know from the past that several entities aren’t required to be licensed under the CFLL,

A. Exemptions
The California Finance Lenders Law provides that
certain entities, persons, and transactions are exempt from
the general licensing requirements. Exempt categories
include:
1. banks, savings and loan associations, credit
unions, certain SBA-approved lenders, and
pawnbrokers regulated by the laws of any state
or by federal law;
2. licensed check cashers;
3. colleges and universities making student loans;
4. securities broker-dealers licensed under California
law
5. persons or entities who make no more than five
commercial loans in a twelve-month period, and
the loans are “incidental” to the primary business
of the person relying on the exemption;
6. certain public entities (including municipal
corporations and government agencies);
7. agricultural cooperatives;
8. certain credit card issuers;
9. loans made or arranged by California-licensed
real estate brokers and secured by a lien on real
property;
10. cemetery brokers;
11. licensed “residential mortgage lenders;”
12. commercial bridge loans made by a venture capital
company to an operating company;
13. franchise loans made by a franchisor to a franchisee;
14. certain commercial loans and other investments
made by certain tax-exempt organizations.

Hedge funds that make loans as part of their portfolio. are not exempt if it is their "only" business ( similar to glass steangal vs Gramm-Leach-Bliley Act)
CFL license is limited in its capabilities. The CFL license permits the licensee to lend, but only from its own balance sheet; meaning it must be the lender of record on all loans it originates and funds. In addition, it is limited in its ability to sell loans. Currently, CFL licensees are only allowed to sell loans to “institutional investors” or other CFL licensees. However, this doesn’t mean there aren’t creative solutions to these restrictions. ( with additional requirements and licencing and experience needed...when i get it il print my name in big bold print ..Elizabeth )

__

*Some of us are on the move to get the "extended" more advanced Licence( its "above" cfl and harder to get)...pushed me out of my comfort zone again and right back into Venture capital and Bridge Capital ( I just wanted to sit in the corner and call clients and get documents in and fund deals and go home- i hate paperwork)

Check the updated regulations and check with a lawyer...there are fines of $2500 each and jail time that can be incurred with each violation

And I am still staying with my favourite funders

__

ADD

___Even though lead generators are not traditionally considered "brokers," these businesses may perform some of the activities for which a CFL license is required. Further, a CFL licensee cannot compensate an unlicensed third party for accepting applications or soliciting loans. Thus, a lead generator may need to be licensed to get paid for leads of California residents provided to a license

***That's the referral business that I have talked about going out the window, and this is the nuclear bomb I have spoken of ***


When you are regulated you cant even take a gift card for more than $100...I am sure some have heard me say by accident ...no gift cards over $99 by accident on the phone..I am on autopilot

_

How Dare someone attacks my credibility when I was 100% right. And say I do not want regulation becacause of a background check ..Unlike some, I have a long successful career in Regulated industries ...not one MARK. My friends in real life said. why do you bother talking to people you wouldn't even say hi to in real life.

Regulation is a nightmare. Gl with it. I know my way around the industries that are regulated 30 years is a long long long long time.

__

Add. West Coast I said Glass Steagall and Graham leach biley act...do I have to say Dodd-Frank and Volcker rule for you to engage?
You and I can go to the capital hill ...some who don't understand finance will be there, and you and I can slug it out...you can quote Von Mises Adam Smith and Keynesian economics...then tell me to behave and I can respond " whatcha talking bout Willis" Someone else can have picket sign "Karen had a dui" as the paparazzi photos go off saying Karen = Elizabeth lol

( not fighting with you west i need another vacation..see you in a week)