California’s Private Postsecondary Colleges Must Now Register with State Department of Financial Protection and Innovation

Duane Morris 

June 11, 2025
The California Department of Financial Protection and Innovation (DFPI) has issued guidance under the California Consumer Financial Protection Law (CCFPL) that impacts private postsecondary colleges operating in the state. The guidance provides that such institutions must register with DFPI as providers of postsecondary education financing even if they allow students to make payments on their tuition, while enrolled in college, with no fees or interest assessed on the tuition balance. Institutions should consider immediately registering with DFPI to avoid substantial potential penalties and other legal liabilities.
In 2020, the California Legislature passed the CCFPL as AB 1864. This law provided the DFPI with authority to oversee several areas of the financial marketplace, including private postsecondary education financing.
On February 7, 2025 (a week prior to the February 15, 2025, effective date), DFPI issued a notice to private postsecondary education institutions to register with DFPI if the institution is “engaging in the business of offering to provide or providing postsecondary education financing to California residents.” As described in Section 1003 of the CCFPL regulations, “education financing” means:

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