What DFPI’s Suspension of FIPVCC Implementation Means for Businesses
Published: May 15, 2026
Originally published by the California Lawyers Association Business Law Section in the Corporations Committee e-Bulletin (2026 issue addressing developments under California’s Fair Investment Practices by Venture Capital Companies Law), this co-authored article originally titled “DFPI Suspends Implementation of the FIPVCC Rulemaking” by Christopher Chediak of Weintraub Tobin’s Corporate Group and Harry Berezin of Goodwin Procter LLP discusses the California Department of Financial Protection and Innovation’s suspension of implementation and enforcement of the Fair Investment Practices by Venture Capital Companies Law pending further rulemaking and guidance.
On March 17, 2026, the California Department of Financial Protection and Innovation (DFPI) announced that it has suspended the implementation and enforcement of the Fair Investment Practices by Venture Capital Companies Law (FIPVCC), pending further rulemaking and guidance. As a result, DFPI will not require covered entities to submit registrations or comply with the reporting obligations of the FIPVCC by the previously announced April 1, 2026 deadline.
The FIPVCC, signed into law by Governor Gavin Newsom through the passage of SB 54 (Stats. 2023, ch. 594) and later amended under SB 164 (Stats. 2024, ch. 41), requires certain entities that invest in startup, early‑stage or emerging growth companies to register with DFPI, administer demographic surveys to portfolio company founding team members, and submit annual reports of aggregated, anonymized data, including information about the founding team members of the companies in which they have invested during the preceding year. Registration opened on March 1, 2026 and the first reports were scheduled to be due April 1, 2026, covering the prior year.
DFPI announced that it intends to initiate the rulemaking process later this year to address interpretive questions and implementation mechanics under the statute, with “the goal of promoting clarity, collaboration, and transparency.” In order to maximize stakeholder engagement, DFPI will “seek input from venture capital companies, industry associations, founders, investors, and other relevant parties over the next few months” prior to the formal beginning of the rulemaking process. Once initiated, the formal rulemaking must be completed within one year.
Covered entities should keep in mind that the FIPVCC remains in effect and the suspension is temporary pending the completion of the rulemaking process and adoption of regulations. It is expected that the scope of future registration and reporting obligations may change. This delay in implementing the FPIVCC will allow time to address material questions that have been raised about the registration and reporting process. Covered entities would be well-advised to continue preparing for the FIPVCC’s implementation to avoid compliance challenges once implementation and enforcement resumes.
This e-Bulletin was prepared by Harry Berezin of Goodwin Procter LLP and Christopher Chediak of Weintraub Tobin Chediak Coleman & Grodin Law Corporation. Mr. Chediak and Mr. Berezin are members of the Corporations Committee of the Business Law Section of the California Lawyers Association. The views expressed herein are those of the authors and do not necessarily reflect the views of their respective law firms or of the California Corporations Committee.