On January 12, 2026, the California Department of Financial Protection and Innovation (DFPI) issued an invitation for comments on a proposed rulemaking concerning registration and reporting for consumer-reporting providers.
Background
In 2024, the DFPI finalized registration and reporting requirements under the California Consumer Financial Protection Law (CCFPL) for four categories of providers of financial products and services. These regulations, effective February 15, 2025, require providers of income-based advances, private postsecondary education financing, debt settlement services, and student debt relief services to register with the DFPI and abide by certain reporting requirements if they offer or provide services to California residents.
In October 2024, the DFPI first sought input on whether to expand the registration and reporting requirements to additional categories of covered persons under the CCFPL. The DFPI’s current request specifically seeks comment on whether to expand coverage to consumer-reporting providers. Interestingly, none of the four comments the DFPI received in response to its October request suggested coverage of consumer-reporting providers.
Request for comment
Under the CCFPL, consumer-reporting providers generally include persons that collect, analyze, maintain or provide consumer report information or other account information, including information relating to a consumer’s credit history, that is used or expected to be used in connection with the decision to offer or provide a consumer financial product or service.[1]
The most common example of a consumer-reporting provider is a credit reporting agency. One focus of the current invitation for comment concerns whether the CCFPL, and therefore the proposed registration and reporting requirements, also apply to intermediaries that assist consumer-reporting agencies, such as data brokers, aggregators, furnishers and resellers of consumer data.
Other questions posed by the DFPI relate to the following topics:
- Benefits and harms to consumers created by consumer-reporting providers
- Concerns stemming from consumer-reporting providers or intermediaries, and whether they warrant prioritizing supervision of the consumer-reporting industry over other industries
- Whether the DFPI should add or clarify existing definitions within the CCFPL as they may apply to consumer-reporting providers
- Recommendations for changing current application requirements or processes, including those related to annual reports and fees
- The anticipated economic impact of imposing additional registration and reporting requirements
- Whether a different financial product or service should instead be subject to registration and reporting requirements
Looking ahead
The DFPI’s invitation for comment signals a clear interest in regulating not only consumer-reporting agencies, but also the related entities that provide or interface with data found in a consumer report. The DFPI’s focus on entities that interface with consumer-reporting agencies mirrors an effort by the Consumer Financial Protection Bureau in late 2024 to bring data brokers and similar entities in the consumer reporting ecosystem under the purview of the Fair Credit Reporting Act. The DFPI’s current efforts to regulate these entities also coincides with other regulatory scrutiny of data brokers in California.
Consumer-reporting agencies, as well as the ancillary businesses that work with these agencies, should examine the DFPI’s request and consider providing comments.
Comments are due by February 26, 2026.
[1] Cal. Fin. Code § 90005(k)(9).