California Senate Bill SB825

California 2025-2026 Regular Session

• Introduced: 10/14/25
• Introduced: 2/21/25
• Refer: 3/12/25
• Refer: 3/24/25
• Report Pass: 4/3/25
• Refer: 4/3/25
• Report Pass: 4/23/25
• Refer: 4/23/25
• Engrossed: 6/3/25
• Refer: 6/9/25
• Report Pass: 7/8/25
• Refer: 7/8/25
• Report Pass: 8/20/25
• Enrolled: 9/10/25
• Chaptered: 10/6/25
• Passed: 10/6/25

Caption

An act to amend Section 90002 of the Financial Code, relating to finance.

Summary

SB 825 amends Section 90002 of the Financial Code, which is part of the California Consumer Financial Protection Law (CCFPL). The bill clarifies that the CCFPL’s exemption for persons acting under certain state-issued licenses, certificates, or charters does not stop the Commissioner of Financial Protection and Innovation from using the CCFPL’s authority to enforce the law’s prohibition on deceptive or abusive acts or practices. In practical terms, the bill preserves the general licensing-based exemption while making clear that the commissioner can still pursue enforcement under Section 90003 against covered conduct. The measure applies to a wide range of DFPI-regulated financial businesses, including escrow agents, finance lenders, mortgage-related licensees, broker-dealers, investment advisers, check sellers, bill payers, proraters, capital access companies, and other entities operating under the Financial Institutions Law. It also preserves the existing exclusion for banks, credit unions, and similar institutions acting under federal or out-of-state authority, while leaving the CCFPL applicable to other covered persons. The bill therefore narrows any argument that licensed status alone shields a business from CCFPL enforcement for deceptive or abusive practices.

Impact

SB 825 does not create a new regulatory program or add a new penalty; instead, it clarifies the scope of an existing exemption in the Financial Code. Its main legal effect is to confirm that DFPI’s commissioner may use CCFPL enforcement authority against licensed financial service providers for deceptive or abusive acts or practices even when those providers are otherwise exempt from some CCFPL provisions because they operate under a DFPI-issued license or charter. This affects the interpretation and enforcement of Section 90002 and reinforces Section 90003 as an enforceable consumer-protection provision across multiple financial sectors.

Sentiment

The bill appears to have had generally favorable support, as reflected in repeated majority votes in committee and on the floor and its eventual chaptering by the Governor. The vote margins suggest broad agreement that the commissioner should retain enforcement authority over deceptive or abusive conduct in the consumer finance market. At the same time, the presence of several no votes at multiple stages indicates that some members had reservations, likely about the reach of DFPI authority or the bill’s effect on licensed financial institutions.

Contention

The main point of contention is the relationship between licensing exemptions and consumer-protection enforcement. Supporters appear to favor making explicit that a license does not function as a blanket shield from CCFPL enforcement for deceptive or abusive practices. Opponents likely worried that the clarification could expand regulatory exposure for licensed entities, including escrow companies, lenders, mortgage businesses, broker-dealers, and other DFPI licensees, by reducing the practical scope of the exemption they previously relied on. The bill’s repeated committee referrals to Appropriations also suggest some concern about administrative or enforcement implications, even though the bill was not an appropriation measure.