SB 694 amends California’s Unfair Competition Law to add several targeted prohibitions and disclosure requirements aimed at protecting service members, veterans, and other consumers from deceptive practices. The bill bars unreasonable fees for assistance in obtaining public social services (explicitly including veterans’ benefits), requires prominent oral and written disclaimers at events about veterans’ benefits, outlaws certain financial products such as cash payments for assignment of pension or veterans’ benefits, and tightens solicitation and advertised-price disclosure rules.
For compliance officers, consumer-facing organizations, and those who run seminars or outreach about veterans’ benefits, the bill creates new document and format requirements (specific on-page and envelope font sizes and verbatim language), an enforceable standard for what counts as an “unreasonable fee,” and expanded prohibitions that intersect with federal veterans benefits rules. The changes reallocate legal risk toward promoters and advertisers while carving narrow exemptions for licensed attorneys and VA-accredited representatives in limited contexts.
At a Glance
What It Does
The bill adds multiple unfair or deceptive practices to the Unfair Competition Law: it prohibits charging an ‘unreasonable fee’ to help prospects obtain public social services (including VA benefits), mandates specific written and oral disclaimers at veterans-benefits events, bans sale or advertising of products illegal under state or federal law (explicitly including cash-for-assignment of pension/veterans benefits), and requires conspicuous solicitation disclosures and full-price advertising including mandatory fees.
Who It Affects
Promoters and advertisers of veterans-benefits seminars; companies and individuals who assist applicants with public social services (including paid preparers); providers of consumer financial products and solicitations; mortgage brokers and lenders in home-improvement financing; and broadband and retail sellers required to display full pricing.
Why It Matters
The bill creates enforceable formatting and content requirements that are easy for regulators and plaintiffs to test (specific wording and font sizes), expands consumer-protection exposure in a niche that targets older veterans and service members, and ties state-level rules to existing federal standards (for example by referencing VA-accredited agent fee benchmarks and FCC broadband labels). That combination makes noncompliance straightforward to prove — and costly to defend.
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What This Bill Actually Does
SB 694 layers new, targeted prohibitions onto California’s existing unfair-competition framework to address an identified pattern: commercial actors who monetize veterans’ and other public-benefit processes through misleading events, high-fee assistance, or disguised financial offers. The bill defines and outlaws charging an “unreasonable fee” to prepare, advise, or assist someone seeking public social services; it explicitly includes assistance related to federal veterans benefits and directs that fees tied to federal veterans benefits cannot exceed what a VA-accredited attorney or claims agent could charge.
On advertising and events, the bill requires any seminar, workshop, or public gathering about veterans’ benefits that is not sponsored or affiliated with the VA or an authorized veterans’ organization to carry an explicit written and oral disclaimer. The statute supplies the required language and mandates that the disclaimer appear in the same type size and font as the word “veteran” in promotional materials and be read and distributed at the start of any such event.
A parallel required statement warns attendees that insurance products promoted are not endorsed by the VA or state veterans’ agencies unless written permission exists.SB 694 also targets certain financial solicitations: it requires covered solicitations for consumer financial products to include the sender’s name and contact information and a bold, large-print disclosure — “THIS IS AN ADVERTISEMENT. YOU ARE NOT REQUIRED TO MAKE ANY PAYMENT OR TAKE ANY OTHER ACTION IN RESPONSE TO THIS OFFER.” — in at least 18-point type in the solicitation and 16-point type on the front of physical envelopes.
The statute clarifies what counts as a solicitation and exempts mass media and consumer-initiated communications. Finally, the bill tightens price-advertising rules to require inclusion of all mandatory fees (with limited exceptions like government-imposed taxes and narrow restaurant/grocery items), and deems compliance with the FCC’s broadband consumer label sufficient for broadband providers.Mechanically, the bill preserves certain defenses and narrow exemptions: attorneys licensed in California remain exempt from the “unreasonable fee” prohibition when representing clients in administrative appeals or court proceedings, and third-party liability for illegal home-solicitation transactions is limited to parties with an agency relationship or actual knowledge.
The text also updates the statutory standard for “clear and conspicuous” to a specified definition and declares an operative date for the amended section.
The Five Things You Need to Know
The bill makes it an unlawful unfair or deceptive practice to charge an "unreasonable fee" to prepare, aid, or advise anyone in procuring public social services — and expressly includes assistance tied to federal veterans benefits in that prohibition.
For any public event, seminar, or workshop about veterans’ benefits that is not sponsored or affiliated with the VA or a recognized veterans organization, the promoter must include and orally read a verbatim disclosure: “I am not authorized to file an initial application for Veterans’ Aid and Attendance benefits on your behalf, or to represent you before the Board of Veterans’ Appeals... It would be illegal for me to accept a fee for preparing that application on your behalf.”, The bill forbids advertising, offering, or selling financial products that are illegal under state or federal law, explicitly listing cash payments for the assignment of a consumer’s future pension or veterans’ benefits as an example.
A covered person soliciting a consumer for a consumer financial product must print the sender’s name and contact information and place the bold 18-point disclosure “THIS IS AN ADVERTISEMENT. YOU ARE NOT REQUIRED TO MAKE ANY PAYMENT OR TAKE ANY OTHER ACTION IN RESPONSE TO THIS OFFER.” in solicitations (16-point on the front of physical envelopes).
Price advertising must include all mandatory fees and charges (with narrow exceptions), and compliance with the FCC’s broadband consumer label is treated as compliance for broadband providers.
Section-by-Section Breakdown
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Prohibits unreasonable fees for assistance obtaining public social services (explicitly including veterans’ benefits)
This provision makes it unlawful to charge or receive an “unreasonable fee” for preparing, aiding, or advising applicants for public social services. It defines public social services to include activities administered by state health and social service agencies and explicitly includes benefits administered by the U.S. Department of Veterans Affairs and the California Department of Veterans Affairs. The statute establishes multi-factor guidance for what counts as “unreasonable” — time and effort, novelty, skill required, relationship length, and the provider’s experience — and creates a specific floor for claims involving federal veterans benefits by tying permissibility to the amount that could be charged by VA-accredited attorneys or claims agents.
Mandatory, verbatim disclaimers for events about veterans’ benefits
This section prescribes exact language and placement for disclosures in advertisements and at the start of any public event addressing veterans’ benefits that is not sponsored by the VA or an authorized veterans organization. The bill requires the first disclaimer (about lacking authority to file or represent before the VA and the illegality of accepting a fee to prepare initial VA applications) in the same font size as the word “veteran” and both orally and in writing at the event’s outset. A separate required notice must state the event is not affiliated with government or recognized veterans groups and that insurance products promoted are not endorsed by those organizations unless written permission exists. These rules create a clear checklist for regulators and private plaintiffs to evaluate compliance.
Prohibits illegal financial products and false 'Made in California' claims
The bill explicitly enumerates as unlawful the advertising, offering, or sale of financial products that are illegal under state or federal law; it calls out cash payments for assignment of future pension or veterans benefits as an example. Separately, it reaffirms that using a Made in California label is unlawful unless the product actually meets the statutory standard under Government Code Section 12098.10. Both provisions tie existing consumer-protection norms to specific illicit practices that have targeted vulnerable populations.
Solicitation format and disclosure requirements for consumer financial offers
This part requires covered persons (as defined under the Financial Code) making solicitations for consumer financial products to include the sender’s name and contact information and a bold, large-type declaration that the mailing is an advertisement and that no payment is required. The statute defines solicitation narrowly to exclude mass advertising, consumer-initiated contacts, and communications already subject to federal disclosure regimes. It also requires the same bold disclosure in the language used in the solicitation and prescribes a 16-point envelope-front disclosure for physical mailings, creating a concrete technical compliance burden for direct-mail campaigns.
All-fees price advertising requirement, FCC broadband-label conformity, mortgage/home-improvement financing restriction, and ‘clear and conspicuous’ update
Paragraph 29 requires advertised prices to include all mandatory fees or charges (excluding government taxes and reasonable postage/shipping charges), with narrow restaurant/grocery exemptions that still demand conspicuous disclosure. For broadband providers, the bill accepts the FCC’s broadband consumer label as compliant with this paragraph. Subdivision (b) forbids mortgage brokers or lenders from using a home-improvement contractor to negotiate loan terms when the loan secures a home-improvement contract. Subdivision (c) updates the statutory standard so that any disclosure required to be “clear and conspicuous” must meet the definition in Section 1791(u). The statute also contains limited third-party-liability rules for home-solicitation violations and an attorney exemption for certain representation scenarios.
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Who Benefits
- Veterans and service members who attend private seminars — the required disclaimers and prohibition on certain paid preparer fees reduce the chance they will be misled or charged exploitative sums when seeking VA benefits.
- Low-income and economically vulnerable claimants seeking public social services — the ‘unreasonable fee’ standard and the tie-back to VA-accredited fee norms create a new avenue to challenge exploitative paid-assistance arrangements.
- Consumers of consumer financial products — larger-format, mandatory solicitation disclosures and all-fees pricing reduce the risk of surprise charges and make direct-mail and targeted offers easier to evaluate.
Who Bears the Cost
- Commercial seminar promoters, insurance agents, and independent preparers who run veterans-benefits events — they must add specific oral and written disclosures, change marketing materials to match font-size rules, and may face enforcement or private suits if they exceed fee norms.
- Direct-marketing teams and lenders that send physical solicitations — these actors must redesign mailings to include 18-point/16-point disclosures and ensure full-fee price displays, increasing production costs and compliance overhead.
- Mortgage brokers, lenders, and home-improvement contractors involved in financing — the restriction on using contractors to negotiate loan terms shifts origination practices and may reduce certain referral-based business models.
Key Issues
The Core Tension
The bill’s core dilemma is this: it seeks to protect vulnerable veterans and service members by imposing bright-line, enforceable disclosure and fee limits, yet those same bright-line rules risk restricting legitimate paid-help and outreach and create substantial compliance costs for small promoters and preparers. Tighter protection reduces exploitation but can also narrow lawful avenues for paid assistance and educational activity, leaving regulators to balance deterrence against denying access to paid services that some consumers legitimately want.
SB 694 creates several implementation and enforcement wrinkles. First, the “unreasonable fee” standard is intentionally multi-factor and fact-specific, which gives enforcement agencies and private plaintiffs flexibility but leaves businesses uncertain about a bright-line maximum.
The cross-reference to amounts VA-accredited attorneys or claims agents "could" charge imports a federal benchmark without setting a numeric cap; that wording may prompt litigation over how to interpret or calculate the comparable amount in a given case.
Second, the event-disclosure regime uses precise, quoted language and font-size parity with the word “veteran.” That clarity helps enforcement, but it also raises practical questions about hybrid events, digital promotions, or multi-lingual materials where font sizes and oral translations complicate literal compliance. The statute exempts certain licensed attorneys and limits third-party liability for home-solicitation schemes, but it does not fully resolve how state enforcement will interact with federal VA rules—particularly where the federal statute or VA regulations already regulate who may charge fees for claims preparation or representation.
Finally, the solicitation and price-disclosure mandates are technically specific (18-point bold type, 16-point on envelopes, full-fee pricing) and therefore easy to audit — but they shift compliance costs to direct-mail and online marketing programs. The broadband-label safe harbor aligns state and federal consumer-labeling regimes, reducing friction for ISPs, but other industries lack equivalent federal templates and may struggle to translate the statute’s format rules into practice.
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