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Mum's the Word at California's Civil Rights Department Regarding Fair Investment Practices by Investment Advisers Law (AKA SB 54)
Thursday, March 14, 2024

wrote about a bill, SB 54, that would have required institutional investors, securities and real estate brokers, and others to report on the diversity status of "founding teams". At the time, I criticized the bill as being "so poorly drafted as to amount to gibberish". In July, I wrote about the bill again, pointing out its nonsensical definition of "covered person". The legislature amended the bill in September, renaming and redefining the category of persons subject to reporting (I don't know whether this was intended to address the concerns raised in my blog post). SB 54 is now law. See Despite Admittedly "Problematic Provisions" Governor Newsom Signs Venture Capital Disclosure Bill.

Recently, I addressed the following questions to California's Civil Rights Department regarding its role in implementing SB 54:

  1. When does the Department intend to release the standardized survey form required by SB 54?
  2. Does the Department intend to propose any implementing regulations? If so, when?
  3. Is the Department a party to any legal challenges with respect to SB 54?

The response that I received was decidedly uninformative: 

Thanks for reaching out. No updates to share on our end at this point in time.

Given the importance of venture capital to California's economy, one might expect that the state would be more proactive in providing information to the industry. See With California's Share Of Venture Capital Investment Falling, California Decides Its A Good Idea To "Bite The Hand That Feeds It"

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