On April 26, 2021, CBA filed a comment letter to the California Department of Financial Protection and Innovation on the implementation of SB 1235, a measure which requires lenders and other commercial financing companies to provide clear and consistent disclosures to small business owners. CBA stated its position that subsidiaries, affiliates and entities otherwise related to depository institutions, which are engaged in the business of commercial lending under federal regulatory oversight should be exempted from application of the proposed regulations in the same manner that depository institutions are exempted.