On Aug. 2, 2023, California’s Department of Financial Protection and Innovation (DFPI) released a new rule expanding its authority to regulate unfair, deceptive, and abusive acts and practices (UDAAP). The rule implements Section 90009(e) of the California Consumer Financial Protection Law (CCFPL), which authorizes the DFPI to issue rules defining UDAAPs for commercial financing. This rule strictly defines UDAAP concerning commercial financing and authorizes the DFPI to include in its UDAAP rulemaking requirements for data collection and reporting on the provision of commercial financing or other financial products and services.

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Photo of Patrick Shannon Patrick Shannon

Patrick Shannon is the Co-Leader of the California Government Law & Policy Group in the firm’s Sacramento office. Patrick focuses his practice on government relations and administrative law before the California legislature and state regulatory and enforcement agencies. He has deep experience on

Patrick Shannon is the Co-Leader of the California Government Law & Policy Group in the firm’s Sacramento office. Patrick focuses his practice on government relations and administrative law before the California legislature and state regulatory and enforcement agencies. He has deep experience on matters relating to financial services, health care, transportation, insurance, environmental regulation, tax, and government contracts.

He has served as outside government relations legal counsel and a top policy strategist in California, principally at the state but also local level, for more than two decades for several of the world’s largest financial institutions, health care companies, and transportation conglomerates.

Patrick has practiced government relations law and otherwise worked in government relations since 1992. He previously headed the firm’s Silicon Valley government practice before founding Government Relations Counsel in 2008. During his prior tenure in state government, he served as Gov. Pete Wilson’s legislative advisor and liaison on business issues and on all civil and criminal justice matters, overseeing six cabinet-level agency legislative programs. In addition to his senior policy advisory work, Patrick has held executive positions in two technology companies, founded his own corporate affairs consulting firm, and practiced securities law at an international law firm.

Photo of Tarrian L. Ellis Tarrian L. Ellis

Tarrian L. Ellis focuses his practice on federal and state regulation of consumer financial products and services, including matters related to fair lending, residential mortgage lending and servicing, student loan servicing, electronic lending, and digital payments. He also advises clients on matters involving…

Tarrian L. Ellis focuses his practice on federal and state regulation of consumer financial products and services, including matters related to fair lending, residential mortgage lending and servicing, student loan servicing, electronic lending, and digital payments. He also advises clients on matters involving the Consumer Financial Protection Bureau (CFPB) and other federal and state regulatory authorities with oversight of consumer financial payments, products, and services.

Prior to joining Greenberg Traurig, he served as a regulatory attorney with the Consumer Financial Protection Bureau in the Office of Regulations. In this role, he participated in complex rulemaking projects, including drafting rules and guidance related to privacy and small business lending, and provided subject matter expertise on issues concerning mortgage servicing and disclosure, and electronic payments.