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This alert is a follow-up to our January 2026 client alert regarding the California Fair Investment Practices by Venture Capital Companies (FIPVCC) Law.
On March 17, 2026, the California Department of Financial Protection and Innovation (DFPI) announced that it is suspending the implementation and enforcement of the FIPVCC pending further rulemaking and guidance. During the suspension period, covered entities are not required to submit registrations or file annual reports.
According to the DFPI, later this year, the agency intends to initiate a rulemaking process to address interpretive questions and implementation mechanics under the statute, with "the goal of promoting clarity, collaboration, and transparency." The DFPI intends to "seek input from venture capital companies, industry associations, founders, investors, and other relevant parties" before it initiates rulemaking. Once initiated, the agency will have one year to complete the rulemaking process.
The DFPI will not enforce the FIPVCC's reporting, recordkeeping, or related obligations prior to completion of the rulemaking process.
Practical Implications
While the suspension provides immediate relief from near-term compliance obligations, covered entities should remain mindful that:
- The FIPVCC statute remains in effect, and the suspension is temporary pending further regulatory action.
- The scope of future requirements will likely evolve.
- Covered entities should continue internal readiness efforts (particularly with respect to tracking investments) to avoid future compliance challenges once implementation resumes.
Goodwin will continue to monitor developments, including the DFPI's rulemaking process and any updated compliance deadlines, and will provide further updates as they become available.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
