According to the Department of Financial Protection & Innovation (“DFPI”), “routine HOA assessments” do not constitute a “consumer credit transaction” as defined under the California Debt Collection Licensing Act (“DCLA”). The collection of routine HOA assessments is not considered a collection of “consumer debt.”  

While the DFPI does not define what constitutes “routine HOA assessments,” its comments on its website suggests that collecting HOA assessments does not require a debt collection license under the California Debt Collection Licensing Act (“DCLA”). The DFPI is a department under the Business, Consumer Services & Housing Agency established to protect consumers from unfair, deceptive, or abusive practices committed by unlicensed financial services.