Monthly Bulletin – March 2025

Updates on DFPI Response to Los Angeles-Area Wildfire

The Department of Financial Protection and Innovation (DFPI) has taken several steps to monitor and respond to the Los Angeles-area wildfires that have cost lives and caused large-scale property damage.

• The Department of Financial Protection and Innovation (DFPI) has taken several steps to monitor and respond to the Los Angeles-area wildfires that have cost lives and caused large-scale property damage.
  1. 90-day mortgage payment forbearance periods, streamlined processes for requesting initial relief without submitting forms or documents, payment options that do not require immediate repayment of unpaid amounts (i.e., no balloon payments) at the end of the forbearance period, and the opportunity for additional relief.
  2. Relief from mortgage-related late fees accruing during the forbearance period for 90 days.
  3. Protection from new foreclosures or evictions for at least 60 days.
  4. Institutions will not report late payments of forborne amounts to credit agencies.

  The relief is available to qualified residents who are customers of these institutions in Los Angeles County.

• DFPI Fire Response Webpages – The DFPI has developed and maintained dedicated webpages to share information and resources for victims of the Los Angeles wildfires.
  • LA Fires Resources Webpage – Includes help for residents, fraud and scam protection, and student loan assistance.
  • Mortgage Relief Resources Webpage – Focuses on mortgage and residence help.
  • Summary of DFPI Response to LA Firestorm – A description of measures taken by the DFPI since the wildfires broke out on Jan. 7.
    • On March 7, we posted a video from our Commissioner, KC Mohseni, in which he explains our relief efforts and thanks the financial institutions that have provided support.

Any support that can be extended to survivors of this disaster is appreciated. A number of disaster assistance programs have been implemented to help individuals, businesses, farmers, and the impacted communities recover. The Commissioner supports and welcomes efforts to accommodate disaster victims in a safe and sound manner. Prudent efforts to modify or restructure loans for disaster victims will not be criticized by examiners.

Final reminder: CCFPL 2024 Commercial Financing Annual Report Due March 15

Pursuant to regulations effective Oct. 1, 2023, any person 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 is required to file an annual report by March 15, 2025 with the Commissioner pursuant to the authority under the California Consumer Financial Protection Law (CCFPL).  

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. To learn more about how to register, please visit the CCFPL Commercial Financing Annual Report Information page 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]. 

Broker-Dealer/Investment Adviser (BDIA) Division Updates

Annual Financial Report Filing is due March 31

Investment Advisers subject to the minimum financial requirements under California Code of Regulations, Title 10, Section 260.237.2, are required to file annual financial reports with the Department within 90 days of the firm’s fiscal year-end. If your fiscal year ended on December 31, 2024, your annual report is due March 31, 2025.

The submitted report must include:

1. A year-to-date balance sheet and income statement prepared in accordance with generally accepted accounting principles (GAAP).
2. A Minimum Financial Requirement Worksheet.
3. A Verification Form, signed under penalty of perjury, affirming that the financial statements and supporting schedules are true and correct to the best knowledge and belief of the signer.

Important: Investment Advisers who have custody of client funds or securities must submit audited financial statements prepared by an independent certified public accountant, along with a supporting schedule of the net worth computation and the verification form. The annual financial reports must be filed via email at [email protected].

Form ADV Annual Updating Amendment is due March 31

Investment Advisers whose fiscal year ends on December 31^st  are required to file the Form ADV annual updating amendment by March 31, 2025

The annual updating amendment of Form ADV, Part 1 and Part 2 must be filed through IARD within 90 days of the firm’s fiscal year-end. When filing, investment advisers may use the “Confirm” brochure option in IARD if there are no material changes, to acknowledge the existing brochure is current without uploading a new PDF version. Please refer to Form ADV Part 1 Instructions and Form ADV Part 2 Instructions for more information.

Note: Information in Form ADV, Part 1 and 2 must be consistent with relevant disclosures elsewhere such as your agreement(s) and any public sources. In addition, firms should maintain only one active firm brochure and one brochure supplement per representative at any given time. Please ensure that older brochures are retired accordingly.

BDIA Online Examination commences March 31, 2025

The Broker-Dealer / Investment Adviser Division is continuing an annual online examination for certain registered Investment Advisers, in accordance with DFPI’s authority under California Corporations Code Section 25241, subdivision (c). This mandatory examination consists of an online examination for Investment Advisers registered with the DFPI, who have their principal place of business in another state.

The online examination for this year is scheduled to commence on March 31, 2025. If selected, the advisory firm will be notified on March 31, 2025, and required to complete and submit the online examination by May 16, 2025. The Division is structuring the exam to be conducted on this population on a four-year cycle. However, an Investment Adviser may be selected for a future examination sooner or later than the estimated four-year cycle.

To communicate the online examination, as well as any follow-up communication, the Division will use the Investment Adviser email as disclosed on the current Form ADV. The business e-mail address must be dedicated to receiving DFPI communications and be monitored by the executive staff of your firm, to ensure prompt attention is paid to communications from DFPI.

If you have any questions or inquiries, please contact the Division at [email protected].

Escrow News and Reminders

Some Escrow Annual Reports Due Mar. 17

Escrow agents are required to submit to the 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 Nov. 30, 2024, your annual report is due Mar. 17, 2025. Please have your CPA email your report to [email protected] by the deadline using a secured, encrypted delivery system. The use of a secured 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].

Escrow Advisory Committee Openings

There are two openings on the Escrow Advisory Committee as follows:

• a representative for small-sized escrow companies.
• a CPA who has escrow agent clients.

The Committee is established in Financial Code Section 17214. The Committee’s purpose, as provided in statute, is to assist the Commissioner in the implementation of the Commissioner’s duties under the Escrow Law. The Committee is comprised of eleven members, including the Commissioner or the Commissioner’s designee. The Commissioner appoints the Committee members, other than those representing Escrow Institute of California and Escrow Agents’ Fidelity Corporation. The Committee meets quarterly at the Department’s office. If you qualify for one of the open positions, you are encouraged to apply by sending a letter of qualifications and resume to the attention of Paul Liang, Assistant Deputy Commissioner at 320 West 4th Street, Suite 750, Los Angeles, California 90013. The deadline for submission is March 31, 2025. Should you have any questions, please contact Paul Liang at (213) 576-7535 or [email protected].

Escrow Bulletin on Social Engineering Scams

The DFPI has issued the following Escrow Bulletin regarding Social Engineering Scams targeting Licensed Escrow Companies (https://dfpi.ca.gov/wp-content/uploads/2025/02/EscrowBulletin0225.pdf). Questions regarding this bulletin should be directed to [email protected].

REMINDER: 2024 Annual Reports for CFL, CDDTL, SLSA, and DCLA Due March 15

Annual reports for 2024 for DFPI Finance Lenders (CFL), Payday Lenders (CDDTL), Student Loan Servicers (SLSA), and Debt Collectors (DCLA) are due by March 15, 2025.

A registered DFPI portal account is required to submit the Annual Report.  To register for a portal account, go to the DFPI’s website here. Licensees are strongly encouraged to begin gathering the data early to ensure timely filing of the 2024 Annual Report.

California Financing Law (CFL)

All DFPI licensees under the California Financing Law (CFL) are required to submit an annual report on or before March 15, 2025, even if the licensee had no business activity in the calendar year 2024. Failure to submit the annual report by the due date will result in penalties pursuant to Financial Code section 22715(b). Click here for a penalty matrix reflecting the penalties assessable based on the late-filing date. For questions about the content of the Report or clarification on the instructions, please email [email protected] or call (866) 275-2677.

California Deferred Deposit Transaction Law (CDDTL)

All licensees under the California Deferred Deposit Transaction Law (CDDTL), also known as payday lending, must submit an Annual Report and Industry Survey (Annual Report) to the DFPI by March 15, 2025, even if the licensee had no business activity in calendar year 2024. Failure to submit the Annual Report by the deadline may result in financial penalties pursuant to Financial Code section 23058 or summary revocation pursuant to Financial Code section 23053. For questions about the content of the Report or clarification on the instructions, please email [email protected].

Student Loan Servicing Act (SLSA)

Each student loan servicer is required to file an annual report with the DFPI on or before March 15, 2025, per Financial Code Section 28146(a) of the Student Loan Servicing Act (SLSA). All student loan servicers licensed prior to Jan. 1, 2024, must file the report, even if no business was conducted. Failure to submit the Annual Report by the due date may result in penalties pursuant to Financial Code Section 28154. For questions about the content of the Report or clarification on the instructions, please email the Student Loan Servicing Program at [email protected].

Debt Collection Licensing Act (DCLA)

All licensees under the Debt Collection Licensing Act (DCLA) must submit an Annual Report to the DFPI by March 15, 2025, per Financial Code section 100021(a). For questions about the content of the Report or clarification on the instructions, please email [email protected] or call (866) 275-2677.

Regulation update

On March 4, 2025, the Office of Administrative Law approved proposed regulations regarding the Debt Collection Licensing Act. The regulations specify annual report requirements and define terms necessary to calculate licensees’ annual pro-rata assessments. The regulations will become effective on July 1, 2025.

Crypto Scam Tracker

On March 10, DFPI announced that through our new partnership with the California Department of Justice (DOJ), we have shut down 26 crypto scam websites and uncovered $4.6 million in consumer losses.

Seven new scam types have been identified in our Crypto Scam Tracker, based on more than 2,668 complaints submitted by consumers in California and across the US last year.

DFPI Secures Settlement with GSPartners, Urges CA Clients to Submit Refund Claims by May 22

On Feb. 20, DFPI announced that Californians who deposited money or crypto with GSPartners are now eligible for a refund, thanks to DFPI. This settlement is an enormous victory for consumers who may have invested in unqualified securities via its multi-level marketing (MLM) platform.

If you or someone you know has put funds into GSPartners, there’s now a limited opportunity to reclaim your funds. Clients have 90 days to submit a claim, from Feb. 21, 2025, to May 22, 2025.

To submit a claim, visit gsbsettlement.com.

mainspringcapitalltd.com is a Fraudulent Website

The DFPI has received information that the website mainspringcapitalltd.com is fraudulently marketing itself as a licensed investment adviser.

The imposter website, mainspringcapitalltd.com, is not associated with a California licensed Investment Adviser.

The imposter website is posing as Mainspring Capital Management LLC, which is a California licensed Investment Adviser (CRD number 168756).

New Contact Information for the DFPI

The DFPI has relocated our Sacramento offices as of March 10, 2025, to the new May Lee State Office Complex. Please save the following address to your records:

To ensure mail is properly delivered to the Department, please use the new address.

Industry News

Statement from Conference of State Bank Supervisors (CSBS) President and CEO Brandon Milhorn on Reports of Federal Banking Agency Consolidation

“Many of the proposals for federal regulatory consolidation being discussed in the media have been debated — and rejected — in the past. We encourage the Administration and Congress to avoid drastic restructuring of the federal banking agencies and instead focus on real and meaningful supervisory reforms that would energize our nation’s community banks and support consumers and small businesses.

State bank supervisors stand ready to work with our federal partners to streamline supervision. However, one-size fits all federal consolidation would upend the existing framework with no clear regulatory benefit, at the expense of public confidence in America’s banks. More.

Federal Reserve Board begins 2025 Survey of Consumer Finances

The Federal Reserve Board in March will begin its regular study of household finances, the Survey of Consumer Finances, which provides the public and policymakers with detailed and important insights into the economic condition of American families.

“This survey is an important source of information on the financial well-being of American families,” Federal Reserve Board Chair Jerome H. Powell said in a letter to prospective survey participants. “Our most recent survey, which took place in 2022, has been important to understanding the different ways that American families experienced the unusual economic conditions surrounding the COVID-19 pandemic.”

Filer Transition to New and Improved EDGAR Begins March 24

The Securities and Exchange Commission is providing extensive guidance and resources to assist filers with upcoming access and account management enhancements to the security of the agency’s Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system. On March 24, a new EDGAR Filer Management dashboard will go live on the SEC’s website, and filers can begin enrolling in “EDGAR Next” by submitting an amended Form ID, which is the application that individuals or companies complete to obtain EDGAR access credentials.

The Commission adopted rule and form amendments referred to as EDGAR Next in September 2024 to improve the ability of filers to securely manage and maintain access to their EDGAR accounts while simplifying the procedures for them to access EDGAR. Enrollment in EDGAR Next will remain open until Dec. 19, 2025. However, filers should enroll no later than Sept. 12, 2025, to avoid interruption in the ability to file.

Upcoming Consumer Education Events

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

Building Wealth Through Financial Literacy    

April 9, 12 – 1 p.m. | Virtual  

In today’s complex financial world, it’s more important than ever to understand and be fluent in the terms, rules, and concepts of money. Learn how financial literacy can help you make informed decisions and build lasting wealth. Register online.  

DFPI’s Financial Literacy Month Resource Webinar

April 23, 12 – 1 p.m. | Virtual 

Follow the Path to Financial Well-being! Register for and join the DFPI’s Financial Literacy Resource Webinar. This year, we are looking into consumer spending behavior. Our webinar’s discussion panel includes industry experts who will share how to better understand what factors influence your financial habits and how they affect your relationship with spending. We will also learn about important California programs that can help pave the way for consumers. Register online. 

LICENSEE ACTIVITY

Bank Activity

Merger

Cornerstone Community Bank, Red Bluff, to merge with and into Plumas Bank, Quincy
Filed: 2/20/25

Credit Union

Merger

North County Credit Union, San Diego, to merge with and into Cabrillo Credit Union, San Diego
Approved: 2/01/25
Effected: 2/01/25

SafeAmerica Credit Union, Pleasanton, to merge with and into NuVision Federal Credit Union, Huntington Beach
Approved: 2/01/25
Effected: 2/01/25

Foreign (Other Nation) Bank Activity

New Office

Allied Irish Banks, p.l.c.
415 Mission Street, San Francisco (Representative Office)
Opened: 2/19/25

Voluntary Surrender of License

DNB Bank ASA
470 Ramona Street, Palo Alto (Representative Office)
Effected: 2/28/25

Foreign (Other State) Bank Activity

New Office

Blue Trust, Inc.
2281 West 190th Street, Torrance (non-insured bank facility)
Filed: 1/31/25

Trust Company Activity

New Trust Company

Parallel Trust Company of California
226 So. Beverly Drive, Beverly Hills (application amended from 150 Spear Street, San Francisco)
Approved: 2/11/25

Money Transmitter Activity

New Money Transmitter

Booking Holdings Financial Services USA LLC
Opened: 2/24/25

PayNearMe Financial, Inc.
Approved: 2/04/25

Acquisition of Control

Thunes Financial Services Inc. to acquire control of Tilia LLC
Approved: 2/18/25

Voluntary Surrender

GroupEx Financial Corporation
Effected: 2/03/25

PointChain Technology USA CA Inc.
Effected: 2/18/2025

Sigue Corporation
Effected: 1/27/25