On June 7, 2021, the Consumer Relations Consortium (CRC) submitted a comment to the Notice of Proposed Rule Making issued by the California Department of Financial Protection and Innovation (DFPI) on April 23, 2021, regarding California’s licensing and application requirements. The CRC focused its comment on the definition of “Branch office” and asked the DFPI to clarify that an employee may work from home without the need for a “Branch office” license so long as specific operational and security criteria are met.

In support of its comment, the CRC cited a similar regulation in Maryland and pointed out that allowing employees to work from home is beneficial to both the industry and consumers. Notably, the Maryland regulation is not tied to a public health crisis. Instead, it allows collections employees to work from home so long as specifically laid out data and operational requirements are met. The CRC provided a copy of the Maryland regulation to the DFPI as a potential guide for updating the DFPI’s current definition of “Branch office.”


The CRC further explained in its comments that allowing employees to work from home benefits consumers by enabling accounts receivable entities to retain quality workers and hire the best people regardless of their geographic proximity to a call center.  Additionally, among other positive impacts, this model benefits the industry by increasing employment opportunities and providing employees greater job satisfaction, which results in a lower turnover rate.

The complete comment submitted by the CRC can be found here.

About the Consumer Relations Consortium

The Consumer Relations Consortium (CRC) is a membership group for forward-thinking organizations that wish to influence the direction of collections compliance, legal strategy, and regulatory policy. The CRC is comprised of more than 60 national companies representing the diverse ecosystem of debt collection including creditors, data/technology providers, and compliance-oriented debt collectors that are larger market participants. Established in 2013, CRC is evolving the debt collection paradigm by engaging stakeholders—including consumer advocates, Federal and State regulators, academic and industry thought leaders, creditors, and debt collectors—and challenging them to move beyond talking points and focus on fashioning real-world solutions that actually improve the consumer experience. CRC is managed by The iA Institute. 

Learn more at www.crconsortium.org.

About the iA institute

The iA Institute is a media company that provides news, education, events and connection for professionals in consumer finance. The iA team believes the value of your time and investment in our content should be undeniable, so we thoughtfully design everything we do with a focus on the details that make a difference. Our initiatives include the flagship website and newsletter insideARM; the Consumer Relations Consortium (CRC) and iA Innovation Council membership groups; the iA Research Assistant and Case Law Tracker premium subscriptions; the iA Strategy & Tech digital conference; and the uniquely engaging annual Women in Consumer Finance event. iA is a certified Woman-Owned business.

Learn more at www.theiainstitute.com

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