Monthly Bulletin December 2025

DFPI News

We Wish You a Joyful and Financially Sound Holiday Season!

As we approach the year-end, let’s celebrate the moments that matter most. Happy Holidays from all of us!

Meet DFPI’s New General Counsel

Governor Newsom announced on November 21, 2025, the appointment of Claudia Quiroz as the new General Counsel for the DFPI. She joined the department on December 3rd and is based in our San Francisco office.

Quiroz has held multiple roles at the U.S. Department of Justice from 2022 to 2025, including Deputy Chief of the Computer Crime and Intellectual Property Section, Director of the National Cryptocurrency Enforcement Team, and Deputy Director of the National Cryptocurrency Enforcement Team. She was an Assistant U.S. Attorney for the U.S. Attorney’s Office, Northern District of California, from 2014 to 2024. Earlier in her career, she was an Associate at K&L Gates LLP and a Law Clerk to the Honorable Micaela Alvarez, Southern District of Texas.

Quiroz is a member of the American Bar Association, Federal Bar Association, Hispanic National Bar Association, and Bar Association of San Francisco. She earned a Juris Doctor degree from the University of Wisconsin Law School and a Bachelor of Science degree in French and Speech Pathology from Marquette University.

Enhanced Consumer Protection

On January 1, 2026, a new law, SB 825 will go into effect that helps to strengthen protection for California consumers. While many California businesses currently engage in best practices and comply with the law, at DFPI, we see many emerging trends indicating risks to consumers in the Golden State, the fourth-largest economy in the world.

This law clarifies that providers of consumer financial products and services, regardless of their licensing status, are subject to the DFPI’s authority to stop unlawful, unfair, deceptive, or abusive acts or practices. This applies to banks, mortgage lenders, escrow agents, brokers, and other entities that DFPI regulates. The law helps ensure that businesses operate on a level playing field and helps DFPI protect California consumers from illegal practices that cost time and money, or worse, may facilitate fraud and scams.  You can read the bill here.

Help for Small Businesses – Transparency in Lending

And there is another new law that takes effect on January 1, 2026. This one can help small businesses better understand the true cost of a loan.

Currently, when these businesses seek capital from providers of commercial financing, they often encounter ambiguous or deceptive terms like “rate” or “interest”. SB 362 will require these providers to use the term “annual percentage rate” or the acronym “APR” in specified circumstances.

This helps to ensure that small business owners are given accurate information from financing providers. Disclosing the APR allows small businesses to better evaluate offers and shop around for the best deal. By reducing the use of ambiguous terms, this law increases transparency in commercial lending and helps to improve small business owners’ understanding of the costs associated with financial offers.

DFPI urges businesses to ask for a copy of the Commercial Financing Disclosures from a broker and a lender, and review the APR before signing a financing contract.

Fake Websites Posing as CA licensees

We recently posted two Consumer Alerts about fake websites.

• Four websites are falsely representing themselves as All Points Escrow Inc., a legitimate California-licensed escrow company.
• A copycat website is fraudulently marketing itself as being affiliated with Lisa M. Roth, a California-licensed investment adviser.

DFPI Takes Legal Action Against Apoyo Financiero

We ordered Apoyo Financiero, Inc. to pay a hefty $1 million penalty for illegally overcharging customers. Additionally, the Concord-based company will pay back more than $218-thousand to customers and stop collecting charges above the legal limit. The company claims on its website to market its services to the underbanked community in the San Francisco Bay Area. Este artículo también está disponible en español.

Escrow News

Some Escrow Annual Reports Due December 15

Escrow agents are required to submit to the DFPI Commissioner an annual report prepared by an independent certified public accountant (Financial Code section 17406) within 105 days after the close of the escrow agent’s fiscal year. The annual report includes audited financial statements and required supplemental information.

If your fiscal year ended on August 31, 2025, your annual report is due by December 15, 2025. Please have your CPA email your report to [email protected] by the deadline using a secure, encrypted delivery system. The use of a secure dropbox is also acceptable. If your CPA is unable to submit the annual report electronically, it can be mailed to Queen Padilla, Senior Financial Institutions Examiner, Escrow Law, Department of Financial Protection and Innovation, 320 West Fourth Street, Suite 750, Los Angeles, CA 90013.

Penalties for failure to file the annual report by the due date or to include required information are $100 per day for the first five days a report is late and $500 per day thereafter (Financial Code section 17408). Failure to file a report or to include any required information may also result in the suspension or revocation of an escrow agent’s license or prompt an immediate examination (Financial Code section 17602.5). For questions about the annual reports, email [email protected].

Banks and Credit Unions News

Banks Must Submit Lists of Offices by Dec. 31

According to Financial Code section 1077, all commercial banks, industrial banks and trust companies are required to file a list of all offices currently maintained and operated by the bank. The report shall designate the type and complete address of each such office. Please note this requirement does not apply to other licensee types, such as foreign banking organizations, credit unions, money transmitters, etc.

For the purposes of section 1077, the DFPI must be provided with the following information on or before December 31, 2025:

• Name of bank
• Popular name of branch offices and facilities
• Office type (include the head office, branch, and facility locations; do not include free-standing ATMs)
• Street address, including city, state, country, and ZIP code.

Responses may be emailed to [email protected] or sent by regular mail to Department of Financial Protection and Innovation, One Sansome Street, Suite 600, San Francisco, CA 94104 Attn: Licensing Section.

Reminder: Banks and Credit Unions to Report Fee Income from NSF and Overdraft Charges

Financial Code section 521 requires state-chartered banks and credit unions to report annually to the Department of Financial Protection and Innovation (DFPI) the revenue they received from fees on nonsufficient funds and overdraft charges during the calendar year. These reports are due by Monday, March 2, 2026, so the DFPI can publish the information on its website by March 31.

On December 31, the DFPI will send an email with a report link to the designated email address of each reporting institution.

Please refer to the FAQs or contact Marilyn Davis at [email protected] (banks) or Kim-Phuong Hoang at [email protected] (credit unions) for more information.

Legal News

Updates for Financial Institutions with Attorney Client Trust Accounts

On September 12, 2024, Governor Gavin Newsom signed into law AB 3279, which imposes certain requirements on financial institutions starting in January 2026 relating to client trust accounts, including both Interest on Lawyers’ Trust Accounts (“IOLTA”) and non-IOLTA trust accounts, maintained by a licensee of the State Bar of California. These requirements are found in Business & Professions Code section 6091.3.

The Department of Financial Protection and Innovation is providing this notice as a courtesy to its licensees. Financial institutions should seek guidance from their counsel. Financial institutions can also contact the State Bar to receive updates and ask questions by sending an email to [email protected]. The State Bar also has information on its website at https://www.calbar.ca.gov/BankingCompliance.

Digital Financial Assets News

Digital Financial Assets Law – Licensing Deadline July 1, 2026

If you engage in digital financial business activity with or on behalf of a California resident and are not otherwise exempt, you will need to submit a Digital Financial Assets Law (DFAL) license application by July 1, 2026 in order to continue serving California residents.

Please refer to our “Preparing for you Application” page on the DFPI website. The National Multi-State Licensing System (NMLS) will be open for application submission in Q1 2026.

Signed by Governor Newsom on October 13, 2023, the DFAL creates a comprehensive regulatory program for many crypto companies providing services to Californians.

For more information, please refer to our FAQs or contact us at [email protected].

California Consumer Financial Protection Law (CCFPL) News

2025 Annual Registration and NMLS Renewal Fees Due December 31, 2025

According to California Code of Regulations, title 10, section 1040, each registrant under the California Consumer Financial Protection Law (CCFPL) is required to pay its annual registration fee (Annual Registration Fee) by December 31.

The Annual Registration Fee represents your pro rata share of the costs and expenses reasonably incurred in the administration of the CCFPL as it relates to registrants, as estimated by the Commissioner, for the ensuing year.

In addition, all CCFPL registrants are required to renew their Nationwide Multistate Licensing System and Registry (NMLS) account and pay the Annual Renewal fee before December 31, 2025. Registrants should be able to pay the invoice for the NMLS Annual Renewal fee when they log on to pay the separate CCFPL annual registration fee invoice.

Invoices for the 2025 Annual Registration Fee and NMLS Renewal Fee have been generated and are now available on NMLS. You must log into your NMLS account to view and pay your invoice(s). Payments must be made directly through NMLS via ACH or credit card by the due date.

If you have not done so already, please create a DFPI Self-Service Portal account and register your designated email address to ensure you receive future important notices and reminders distributed to all CCFPL registrants. As a reminder, CCFPL registrants are required to register a designated email address with the DFPI within 5 days after receiving registration approval according to California Code of Regulations, title 10, 1031.

If you have any questions or concerns, please contact [email protected] or call (866) 275-2677 and use the directory to locate the Supervision and Registration of New Covered Persons program. 

CCFPL 2025 Commercial Financing Annual Report Due March 15, 2026

According to regulations effective October 1, 2023, if you are engaged in the business of offering or providing commercial financing or another financial product or service to a small business, nonprofit, or family farm, as defined by California Code of Regulations, title 10, sections 1060(f), (h), and (i), whose activities are principally directed or managed from California, you are required to file an annual report with the Commissioner of the Department of Financial Protection and Innovation (DFPI) according to the authority under the California Consumer Financial Protection Law (CCFPL). The Commercial Financing Annual Report is due by March 15, 2026.

An entity is exempt from filing this report if it made no more than one commercial financing transaction to covered entities in a 12-month period or made five or fewer commercial financing transactions to covered entities in a 12­-month period that are incidental to the business of the entity relying on this exemption. 

A California Financing Law (CFL) licensee must not include commercial financing activity conducted under the authority of that license in this annual report. 

CCFPL Commercial Financing Annual Reports must be submitted electronically through the DFPI Self-Service portal. If you filed the report last year, this year’s report will be available in your registered portal account on January 2, 2026. If you are new to filing this report, you will need to create a portal account and request the report to be generated for you. To learn more about how to create a portal account and request the report to be generated, please visit the CCFPL Commercial Financing Annual Report Informationpage on the DFPI website.

To receive ongoing updates, subscribe on the DFPI website. Once logged in, scroll and choose “Commercial Financing Annual Report” under the category “NCP.” If you have any questions, please contact [email protected] or call (866) 275-2677 and use the directory to locate the Supervision and Registration of New Covered Persons program. 

NEW: CCFPL 2025 Annual Reports Due March 15, 2026

According to California Code of Regulations, title 10, section 1041(a), every registrant under the California Consumer Financial Protection Law (CCFPL) is required to submit an Annual Report to the Commissioner of the Department of Financial Protection and Innovation (DFPI), even if the registrant had no business activity in calendar year 2025. The deadline to submit the CCFPL Annual Report is March 15, 2026.

We strongly recommend registrants start reviewing the requirements and gathering data now to ensure they can timely file their 2025 CCFPL Annual Report.

CCFPL Annual Reports must be submitted electronically through the DFPI’s Self-Service Portal. To submit the CCFPL Annual Report registrants are required to have a registered DFPI Self-Service Portal account. If you have not created a DFPI Self-Service Portal account, please do so now. In addition, please also ensure you have registered your designated email address on the portal to ensure you receive important notices, reminders, and other relevant information concerning the CCFPL Annual Report requirement.

For more information, including a blank copy of the CCFPL Annual Report for each registration type, you can visit the CCFPL Information for New Registrants and other registration type specific (Debt Settlement Services, Student Debt Relief Services, Income-Based Advances, or Education Financing) webpages on the department’s website.

If you have any questions or concerns about your Annual Report, please contact [email protected] or call (866) 275-2677 and use the directory to locate the Supervision and Registration of New Covered Persons program.

Debt Collection News

PRO 05-21 – Invitation for Comments – Debt Collection Licensing Act (DCLA) by December 12, 2025

On August 29, 2021, the DFPI sought comments on this potential rulemaking. On July 15, 2022, the Commissioner released a draft text related to the scope, annual report, and document retention requirements of the DCLA for public comment, prior to the initiation of formal rulemaking. On November 9, 2023, the Commissioner released a second draft text for comment. The Commissioner has again made changes to the draft text and is now releasing it for a third round of prefiling public comment. This draft concerns only the scope and document retention requirements of the DCLA. Regulations concerning annual report requirements were approved on March 4, 2025, and became effective July 1, 2025.

 Invitation and Draft Text

• Invitation for Comments – PRO 05-21 – Invitation for Comments (PDF)
• Third Draft Text – PRO 05-21 – Third Draft Text (PDF)

Time for Comments

The Commissioner invites interested parties to submit comments by December 12, 2025. Submit comments by any of the following methods:

• By email to: [email protected] (please include “PRO 05-21” in the subject line; Comments submitted as attachments in Microsoft Word format (.docx) are preferred.
• By postal mail to: Department of Financial Protection and Innovation / Attn: Diana Pha, Regulations Coordinator, Legal Division, 651 Bannon Street, Ste. 300, Sacramento, CA 95811

For questions, contact Emily Gallagher, Senior Counsel, at [email protected].

Debt Collection Licensing Act (DCLA) – Annual Assessment Due January 1, 2026

All licensees under the Debt Collection Licensing Act (DCLA) are required to submit payment of the annual assessment to the DFPI by January 1, 2026, according to Financial Code section 100020. Failure to timely pay the annual assessment by the due date may result in penalties according to Financial Code section 90012, subdivision (c) for any violation of up to $25,000 for each day and statutory penalties according to Financial Code section 100020, subdivision (b). In addition, according to Financial Code section 100020, subdivision (d), failure to pay the annual assessment by the due date may result in an order summarily revoking the DCLA license. Moreover, failure to timely pay the annual assessment by the due date may result in a claim against the surety bond. Notice with the annual fee schedule was sent to each licensee on September 30, 2025.

 For questions about the annual assessment, please email [email protected] or call (866) 275-2677.

Broker-Dealer and Investment Adviser News

2026 Renewal Program Calendar for Broker-Dealers and Investment Advisers

On Monday, November 10, 2025, Preliminary Renewal Statements will be available through E-Bill on FINRA.

On Monday, November 24, 2025, a DFPI Reminder Email will be sent to all licensees to renew their licenses for the calendar year 2026. Licensees should ensure they have an active designated email address on file with the Department. Please refer to the “Broker-Dealer Information” and “Investment Adviser Information” sections on the Broker-Dealers and Investment Advisers page for more information about the designated email requirements.

On Monday, December 08, 2025, renewal payments are due. This is the deadline for receipt of Preliminary Renewal Statement payments. Review the Renewal Program Payment Options for detailed information. FINRA recommends using E-Bill to pay your Preliminary Statement. Otherwise, please submit your payment allowing sufficient time for mail delivery and/or payment processing to post to your Renewal Account by the deadline.

Remember FINRA-registered firms that do not have payment posted by the deadline may be assessed a Renewal Late Fee.

Friday, December 26, 2025 is the last day to submit form filings prior to year-end. Web CRD and IARD are available from 5 a.m. until 6 p.m. Eastern Time (ET).

Effective May 1, 2024, each investment adviser representative with a full year of registration must annually complete 12 credits of continuing education (six credits of Products and Practice and six credits of Ethics and Professional Responsibility). The continuing education must be completed by the representative and reported by the approved course provider before IARD shuts down for the year on December 26, 2025, at 4:00 pm E.T.

Effective July 1, 2025, the initial and renewal registration fee for broker-dealer agents and investment adviser representatives increased to $50 according to Assembly Bill No. 137. This new fee will be reflected on FINRA E-Bill accordingly.

Please note that on Saturday, December 27, 2025, Web CRD and IARD will be unavailable due to FINRA Statement and renewals processing.

From Sunday, December 28, 2025 – Wednesday, December 31, 2025, Web CRD and IARD will be available for QUERY- and the creation of “Pending” filings.

Mortgage News

DFPI MLO Renewal Requirements

The Department of Financial Protection and Innovation (DFPI) would like to remind you that the NMLS Annual Renewal Period for Mortgage Loan Originators (MLO) began on November 1, 2025, and will end on December 31, 2025.

All licenses that have an approved or approved-equivalent status between January 1^st and October 31^st of the current year (2025) are subject to the renewal process.

To request renewal of your DFPI MLO license, you are required to submit a new Criminal Background Check and pay the renewal fee of $300. The reinstatement period is from January 1, 2026, to February 28, 2026, and requires a reinstatement fee of $100 in addition to the normal renewal licensing fees. Failure to submit a renewal or reinstatement request by February 28, 2026, will require the submission of a new license application and will be subject to the processing timelines for new license applications. All fees are non-refundable.

Consult with your sponsoring company to determine whether you are responsible for renewing your licenses in NMLS or if they are performing this task on your behalf. A free Online Renewal Training Course is available to help guide you through the renewal process.

To ensure that your request for renewal is approved and processed in a timely manner, we encourage you to address any outstanding license items and complete your continuing education well in advance of December 31, 2025. Continuing education credits can take 10-16 days to post to your account in NMLS. If continuing education is not posted to your account by December 31, 2025, you will be required to pay the additional $100 reinstatement fee in addition to the $300 fee for renewal. All fees are non-refundable.

California Financial Code(s) 10 CCR 1950.122.5(g) and 1422.6(g) require amendments to your MU4 to be submitted within 20 days of any change to the information contained in the MU4.

1. Your NMLS record must be up to date, and all state-specific requirements must be met before submitting your renewal request. Visit the Annual Renewal page of the NMLS Resource Center for more information regarding state renewal deadlines, fees, state-specific requirements, continuing education, and more.
2. Failure to address license items related to disclosure items can result in the DFPI preventing your ability to renew your license and/or denying your request for renewal.
3. Certain NMLS support options are available using an online support request. These options include account password reset/unlock, account email changes, and license/registration renewal status. The options are available for both individual and company users. Support Request Forms can be found here.

All fees are non-refundable. This includes refunds for renewals that are denied or submitted in error. Additionally, the DFPI does not offer waivers for required fees, including but not limited to the reinstatement fee for renewals submitted on or after January 1, 2026.

Upcoming Consumer Education Event

Every month we educate consumers through community events and a monthly webinar.

Protect Yourself from Tax Scams Webinar
Jan. 7, 1 – 2 p.m.

Tax season is prime time for scammers trying to steal your tax return and sensitive information. From aggressive phone calls demanding tax payments to sophisticated email phishing campaigns, these tactics are constantly evolving and becoming more convincing. Join this webinar to empower yourself with the knowledge to stay safe and secure this tax season.

Register here.