[jcoop]

Since this passed, are all brokers required to have a CFL to do California deals?

[jcoop]

I couldn't find it that language in bill text, but I may have missed it. https://leginfo.legislature.ca.gov/f...01720180SB1235

[Sean Cash]

Since this passed, are all brokers required to have a CFL to do California deals?

For the most part that's already required. To plug the loopholes, they introduced this: https://leginfo.legislature.ca.gov/f...01720180AB3207

[jcoop]

So we will need a CFL in January?

[Sean Cash]

So we will need a CFL in January?

With the exception of MCA purchase transactions, you already need one.

[BB_Cooper]

SB-1235 is a disclosure requirement that applies to MCA's equally. But where does it impact the already existing licensing requirements?

[Sean Cash]

But where does it impact the already existing licensing requirements?

it doesn't. They had a whole separate bill for that. AB 3207

[Karen37a]

http://leginfo.legislature.ca.gov/fa...ml?tocCode=FIN

Here is 80,000 pages of regulations that everyone can sift through. ( not as much as the Dodd-frank act so that's good) But you must read through it as well if its a lending transaction

Here is the Dodd-Frank Act. Its on 23,000 pages ( roll back)

https://searchcompliance.techtarget....odd-Frank-bill

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Calif DBo will be overseeing them

DBO Directs 20 Lenders with High Triple-Digit APR Levels to Submit Information on Lead Generation Activity
09/26/2018
SACRAMENTO – The Department of Business Oversight (DBO) today directed 20 consumer instalment lenders with high levels of triple-digit APR loans to submit data and other information related to their online lead generation activities.

( business cash advances are next ..online lead generation...imo)


The majority of the litigation concerning cash advances have come out of California. The most prominent is Richard B. Clark, et al. v. AdvanceMe, Inc. under which AdvanceMe agreed to a settlement payment of $23.4 million and forfeited the right to pursue further payments from the plaintiff merchants.

( contracts should be plain English and maybe 4-5 pages IMO )

Avoid Enforcement Action

States can impose harsh penalties on businesses that offer commercial loans without lender licenses or that charge usurious interest rates. However, there were a few cases that address the issue of what constitutes a sale as opposed to a loan in the MCA context.

The Attorney Generals step in as well when they think it crossed over

I will not be deciphering any of it going forwards...all the experts can


** and I am not an Attorney I only play one on TV

[Karen37a]

When you want the securities laws and books etc for the money that goes into the cash advances let me know ill post them and all the regulatory bodies associated.

Also syndication and selling away online referrals to a regulated entity

ask by end of year when you study all those above
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This was a great regulation debate as well.....when they were trying to conjure up the fantasy of making mca brokers have a "fiduciary Duty or obligation"

https://dailyfunder.com/showthread.p...3-BFS-Bullsh*t

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one year from now ill post the 24000 pages of Fiduciary Text some have to make it through ..if anyones left but a few people and me

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https://www.youtube.com/watch?v=aNyK6EcHlzM

Here is the California Regulation song " Hotel Calif"

Welcome to the Hotel California
Such a lovely place (such a lovely place)
Such a lovely face.
They livin' it up at the Hotel California
What a nice surprise (what a nice surprise), bring your alibis
Mirrors on the ceiling,
The pink champagne on ice
And she said, 'we are all just prisoners here, of our own device'
And in the master's chambers,
They gathered for the feast
They stab it with their steely knives,
But they just can't kill the beast
Last thing I remember, I was
Running for the door
I had to find the passage back to the place I was before
'Relax' said the night man,
'We are programmed to receive.
You can check out any time you like,
But you can never leave!'