Changes to California Consumer Law Protections on January 1, 2022
Publications
January 19, 2022
Effective January 1, 2022, California implemented several important changes to its consumer protection laws, ranging from data privacy to debt collection to updates to the Consumer Legal Remedies Act. This post highlights several notable changes that companies and practitioners may wish to bear in mind as they ring in the new year.
Data Privacy
In the world of data privacy, there has been a lot of buzz around California’s new consumer privacy law, the California Privacy Rights Act (CPRA), which was previously discussed on this blog here.
The CPRA will greatly expand the state’s current data protection infrastructure by, among other things, increasing consumer control over sensitive personal information, adding additional consumer privacy rights, and creating the California Privacy Protection Agency to enforce the CPRA.
While not effective until January 1, 2023, the CPRA will apply to certain data collected in 2022, requiring many businesses to begin updating their data practices now.[1]
Debt Collection
A number of the California consumer law updates that took effect on January 1, 2022 focused on debt collection practices. Perhaps most notable is the implementation of the Debt Collection Licensing Act (DCLA).[2] Aligning California with the majority of states that already have collection agency licensure requirements, the DCLA requires debt collectors and debt buyers operating in California to obtain a license from the Department of Financial Protection and Innovation.
The DCLA generally applies to entities collecting consumer debt in California, including organizations such as law firms and other companies engaged in collection activities who may not consider themselves “debt collectors” in the traditional sense. Critically, under the DCLA, debt collectors who missed the December 31, 2021 application deadline must halt operations in California until they are issued a license.[3]
Other changes to California debt collection laws effective January 1, 2022 include:
- Health Care Debt and Fair Billing: Among other things, AB 1020 revises the state’s medical billing and debt collection policies, including by prohibiting hospitals from selling patient debt unless certain conditions are met.[4]
- Identity Theft: AB 430 expands protections for victims of identity theft and requires debt collectors to pause collection activities until certain criteria are met if a consumer submits either a copy of a Federal Trade Commission (FTC) identify theft report or a police report.[5]
- Fair Debt Settlement Practices Act: Adds new regulatory requirements and prohibitions on debt settlement service providers and payment processor activities. It also creates a consumer private right of action for intentional violations, with available remedies including actual damages, injunctive relief, attorneys’ fees, and/or statutory damages as high as $5,000 per violation.[6]
Consumer Legal Remedies Act
January 1, 2022 also saw revisions to the California Consumer Legal Remedies Act (CLRA).[7] As amended, the CLRA now offers additional protections to senior citizens from unfair and deceptive loan solicitations. Specifically, as amended the CLRA now applies to Property Assessed Clean Energy (PACE) program loans for seniors—such as loans for solar panels or energy efficient appliances. Violations are subject to $5,000 in statutory damages, on top of any actual or punitive damages, injunctive relief, restitution, and/or attorneys’ fees.[8]
* * *
Taken together, California has added significant additional complexity and potential liability to the consumer protection landscape at the outset of 2022, and companies who work in these spaces should be careful to ensure that their existing practices are updated to comply with the new laws.
Data Privacy
In the world of data privacy, there has been a lot of buzz around California’s new consumer privacy law, the California Privacy Rights Act (CPRA), which was previously discussed on this blog here.
The CPRA will greatly expand the state’s current data protection infrastructure by, among other things, increasing consumer control over sensitive personal information, adding additional consumer privacy rights, and creating the California Privacy Protection Agency to enforce the CPRA.
While not effective until January 1, 2023, the CPRA will apply to certain data collected in 2022, requiring many businesses to begin updating their data practices now.[1]
Debt Collection
A number of the California consumer law updates that took effect on January 1, 2022 focused on debt collection practices. Perhaps most notable is the implementation of the Debt Collection Licensing Act (DCLA).[2] Aligning California with the majority of states that already have collection agency licensure requirements, the DCLA requires debt collectors and debt buyers operating in California to obtain a license from the Department of Financial Protection and Innovation.
The DCLA generally applies to entities collecting consumer debt in California, including organizations such as law firms and other companies engaged in collection activities who may not consider themselves “debt collectors” in the traditional sense. Critically, under the DCLA, debt collectors who missed the December 31, 2021 application deadline must halt operations in California until they are issued a license.[3]
Other changes to California debt collection laws effective January 1, 2022 include:
- Health Care Debt and Fair Billing: Among other things, AB 1020 revises the state’s medical billing and debt collection policies, including by prohibiting hospitals from selling patient debt unless certain conditions are met.[4]
- Identity Theft: AB 430 expands protections for victims of identity theft and requires debt collectors to pause collection activities until certain criteria are met if a consumer submits either a copy of a Federal Trade Commission (FTC) identify theft report or a police report.[5]
- Fair Debt Settlement Practices Act: Adds new regulatory requirements and prohibitions on debt settlement service providers and payment processor activities. It also creates a consumer private right of action for intentional violations, with available remedies including actual damages, injunctive relief, attorneys’ fees, and/or statutory damages as high as $5,000 per violation.[6]
Consumer Legal Remedies Act
January 1, 2022 also saw revisions to the California Consumer Legal Remedies Act (CLRA).[7] As amended, the CLRA now offers additional protections to senior citizens from unfair and deceptive loan solicitations. Specifically, as amended the CLRA now applies to Property Assessed Clean Energy (PACE) program loans for seniors—such as loans for solar panels or energy efficient appliances. Violations are subject to $5,000 in statutory damages, on top of any actual or punitive damages, injunctive relief, restitution, and/or attorneys’ fees.[8]
* * *
Taken together, California has added significant additional complexity and potential liability to the consumer protection landscape at the outset of 2022, and companies who work in these spaces should be careful to ensure that their existing practices are updated to comply with the new laws.
[1] Cal. Civ. Code § 1798.130.
[2] Cal. Fin. Code § 100000 et seq.
[3] Debt Collection – Licensee, Department of Financial Protection & Innovation.
[4] Cal. Civ. Code §§ 1788.14, 1788.52, 1788.58, 1788.185; Cal. HSC § 127400 et seq.
[5] Cal. Civ. Code §§ 1788.18, 1788.61, 1798.92, 1798.93; Cal. Penal Code § 530.8.
[6] Cal. Civ. Code § 1788.300 et seq.
Footnotes
[1] Cal. Civ. Code § 1798.130.
[2] Cal. Fin. Code § 100000 et seq.
[3] Debt Collection – Licensee, Department of Financial Protection & Innovation.
[4] Cal. Civ. Code §§ 1788.14, 1788.52, 1788.58, 1788.185; Cal. HSC § 127400 et seq.
[5] Cal. Civ. Code §§ 1788.18, 1788.61, 1798.92, 1798.93; Cal. Penal Code § 530.8.
[6] Cal. Civ. Code § 1788.300 et seq.
Related Lawyers
Related Capabilities
Related Locations
© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.
Publications
January 19, 2022
Effective January 1, 2022, California implemented several important changes to its consumer protection laws, ranging from data privacy to debt collection to updates to the Consumer Legal Remedies Act. This post highlights several notable changes that companies and practitioners may wish to bear in mind as they ring in the new year.
Data Privacy
In the world of data privacy, there has been a lot of buzz around California’s new consumer privacy law, the California Privacy Rights Act (CPRA), which was previously discussed on this blog here.
The CPRA will greatly expand the state’s current data protection infrastructure by, among other things, increasing consumer control over sensitive personal information, adding additional consumer privacy rights, and creating the California Privacy Protection Agency to enforce the CPRA.
While not effective until January 1, 2023, the CPRA will apply to certain data collected in 2022, requiring many businesses to begin updating their data practices now.[1]
Debt Collection
A number of the California consumer law updates that took effect on January 1, 2022 focused on debt collection practices. Perhaps most notable is the implementation of the Debt Collection Licensing Act (DCLA).[2] Aligning California with the majority of states that already have collection agency licensure requirements, the DCLA requires debt collectors and debt buyers operating in California to obtain a license from the Department of Financial Protection and Innovation.
The DCLA generally applies to entities collecting consumer debt in California, including organizations such as law firms and other companies engaged in collection activities who may not consider themselves “debt collectors” in the traditional sense. Critically, under the DCLA, debt collectors who missed the December 31, 2021 application deadline must halt operations in California until they are issued a license.[3]
Other changes to California debt collection laws effective January 1, 2022 include:
- Health Care Debt and Fair Billing: Among other things, AB 1020 revises the state’s medical billing and debt collection policies, including by prohibiting hospitals from selling patient debt unless certain conditions are met.[4]
- Identity Theft: AB 430 expands protections for victims of identity theft and requires debt collectors to pause collection activities until certain criteria are met if a consumer submits either a copy of a Federal Trade Commission (FTC) identify theft report or a police report.[5]
- Fair Debt Settlement Practices Act: Adds new regulatory requirements and prohibitions on debt settlement service providers and payment processor activities. It also creates a consumer private right of action for intentional violations, with available remedies including actual damages, injunctive relief, attorneys’ fees, and/or statutory damages as high as $5,000 per violation.[6]
Consumer Legal Remedies Act
January 1, 2022 also saw revisions to the California Consumer Legal Remedies Act (CLRA).[7] As amended, the CLRA now offers additional protections to senior citizens from unfair and deceptive loan solicitations. Specifically, as amended the CLRA now applies to Property Assessed Clean Energy (PACE) program loans for seniors—such as loans for solar panels or energy efficient appliances. Violations are subject to $5,000 in statutory damages, on top of any actual or punitive damages, injunctive relief, restitution, and/or attorneys’ fees.[8]
* * *
Taken together, California has added significant additional complexity and potential liability to the consumer protection landscape at the outset of 2022, and companies who work in these spaces should be careful to ensure that their existing practices are updated to comply with the new laws.
Data Privacy
In the world of data privacy, there has been a lot of buzz around California’s new consumer privacy law, the California Privacy Rights Act (CPRA), which was previously discussed on this blog here.
The CPRA will greatly expand the state’s current data protection infrastructure by, among other things, increasing consumer control over sensitive personal information, adding additional consumer privacy rights, and creating the California Privacy Protection Agency to enforce the CPRA.
While not effective until January 1, 2023, the CPRA will apply to certain data collected in 2022, requiring many businesses to begin updating their data practices now.[1]
Debt Collection
A number of the California consumer law updates that took effect on January 1, 2022 focused on debt collection practices. Perhaps most notable is the implementation of the Debt Collection Licensing Act (DCLA).[2] Aligning California with the majority of states that already have collection agency licensure requirements, the DCLA requires debt collectors and debt buyers operating in California to obtain a license from the Department of Financial Protection and Innovation.
The DCLA generally applies to entities collecting consumer debt in California, including organizations such as law firms and other companies engaged in collection activities who may not consider themselves “debt collectors” in the traditional sense. Critically, under the DCLA, debt collectors who missed the December 31, 2021 application deadline must halt operations in California until they are issued a license.[3]
Other changes to California debt collection laws effective January 1, 2022 include:
- Health Care Debt and Fair Billing: Among other things, AB 1020 revises the state’s medical billing and debt collection policies, including by prohibiting hospitals from selling patient debt unless certain conditions are met.[4]
- Identity Theft: AB 430 expands protections for victims of identity theft and requires debt collectors to pause collection activities until certain criteria are met if a consumer submits either a copy of a Federal Trade Commission (FTC) identify theft report or a police report.[5]
- Fair Debt Settlement Practices Act: Adds new regulatory requirements and prohibitions on debt settlement service providers and payment processor activities. It also creates a consumer private right of action for intentional violations, with available remedies including actual damages, injunctive relief, attorneys’ fees, and/or statutory damages as high as $5,000 per violation.[6]
Consumer Legal Remedies Act
January 1, 2022 also saw revisions to the California Consumer Legal Remedies Act (CLRA).[7] As amended, the CLRA now offers additional protections to senior citizens from unfair and deceptive loan solicitations. Specifically, as amended the CLRA now applies to Property Assessed Clean Energy (PACE) program loans for seniors—such as loans for solar panels or energy efficient appliances. Violations are subject to $5,000 in statutory damages, on top of any actual or punitive damages, injunctive relief, restitution, and/or attorneys’ fees.[8]
* * *
Taken together, California has added significant additional complexity and potential liability to the consumer protection landscape at the outset of 2022, and companies who work in these spaces should be careful to ensure that their existing practices are updated to comply with the new laws.
[1] Cal. Civ. Code § 1798.130.
[2] Cal. Fin. Code § 100000 et seq.
[3] Debt Collection – Licensee, Department of Financial Protection & Innovation.
[4] Cal. Civ. Code §§ 1788.14, 1788.52, 1788.58, 1788.185; Cal. HSC § 127400 et seq.
[5] Cal. Civ. Code §§ 1788.18, 1788.61, 1798.92, 1798.93; Cal. Penal Code § 530.8.
[6] Cal. Civ. Code § 1788.300 et seq.
Footnotes
[1] Cal. Civ. Code § 1798.130.
[2] Cal. Fin. Code § 100000 et seq.
[3] Debt Collection – Licensee, Department of Financial Protection & Innovation.
[4] Cal. Civ. Code §§ 1788.14, 1788.52, 1788.58, 1788.185; Cal. HSC § 127400 et seq.
[5] Cal. Civ. Code §§ 1788.18, 1788.61, 1798.92, 1798.93; Cal. Penal Code § 530.8.
[6] Cal. Civ. Code § 1788.300 et seq.
Related Lawyers
Related Capabilities
Related Locations
© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.
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