Based on the above statement from the Department's website, collection of routine HOA assessments does not require licensure under the DCLA. This will remove some of the uncertainty regarding the potential need to seek and obtain a debt collector license for those entities engaged in assessment collection efforts. There are still a myriad of other debt collection statutes, over and above the DCLA, that potentially apply to and regulate entities involved in assessment collection efforts. The above statement from the Department's website only applies to the DCLA and does not preclude application of those other debt collection statutes, such as the Federal Fair Debt Collection Practices Act or the California Rosenthal Fair Debt Collection Practices Act. 

We were not able to locate any information on the DFPI website regarding what the DFPI considers a "routine HOA assessment." The implication is that collection of non-routine assessments would not be exempt. Further, the DFPI has not issued any guidance that we could locate on whether collection of other typical association charges (e.g., transfer fees, user fees, cable charges, water bills, pool key charges, and special assessments) might trigger licensure. Hopefully the DFPI will continue to interpret and apply the DCLA in a way that recognizes that unpaid association charges are not really consumer debts, and thus collection of unpaid association charges should not require licensure under the DCLA.