California’s Credit Unions remains actively engaged in the implementation of the 2024 reforms to the Private Attorneys General Act (PAGA).

As part of this effort, the California league participated in the California Labor and Workforce Development Agency’s (LWDA) public proceedings on April 9, building on formal written comments submitted on March 23 as part of a broad coalition led by the California Chamber of Commerce.

The proposed regulations issued by the LWDA aim to address long-standing concerns regarding one of the state’s most frequently abused statutes. While PAGA was intended to protect workers, it has increasingly been used as a tool for predatory litigation — forcing employers into costly settlements over technicalities rather than substantive labor issues.

The current proposal focuses on three critical pillars of reform:

• Heightened Specificity: Moving away from “boilerplate” legal notices to require detailed factual allegations before a claim can proceed.
• Accountability for High-Frequency Filers: Increasing scrutiny on a small group of law firms and “vexatious” litigants responsible for a disproportionate number of filings.
• Expanded Opportunities to Cure: Creating a more robust pathway for employers — particularly small institutions — to correct unintentional errors and avoid the courtroom entirely.

Throughout the process, California’s Credit Unions has emphasized the need for a more balanced and workable framework — one that preserves the statute’s intent to address legitimate workplace concerns, while discouraging practices that drive excessive litigation and costs. As reflected in the April 9 proceedings, the California league’s advocacy has also underscored the importance of achieving greater finality in settlements and ensuring appropriate consequences for misuse of the statute.

Because credit unions are not-for-profit and member-owned institutions, the downstream costs of meritless litigation are ultimately borne by the members they serve — underscoring the need for reforms that promote fair compliance over legal gamesmanship.

California’s Credit Unions will continue working alongside coalition partners and the LWDA to advocate for meaningful, practical reforms and will keep credit union leaders informed as the rulemaking process moves forward.