Monthly Bulletin November 2025

DFPI News

Honoring Those Who Have Served

This Veterans Day, we honor and thank all who have served in our armed forces. Your dedication, sacrifice, and courage protect the freedoms we all enjoy.

The DFPI is proud to support California’s veterans and military families by promoting financial protection, education, and access to resources.

To learn more, go to an event near you: https://dfpi.ca.gov/events/.

Legislation Updates

In case you missed it, Governor Newsom recently signed several significant consumer protection-related bills into law, including:

SB 362 – Helps ensure small business owners are given accurate information from financiers.

SB 610 – Expands disaster mortgage relief.

SB 822 – California became the first state in the country to add digital assets to be considered unclaimed property.

SB 825 – Strengthens DFPI’s authority against bad actors.

Youth Banking Report

The San Francisco Office of Financial Empowerment published its 2025 Youth Banking Report developed in collaboration with young leaders from CalMoneySmart grantee MyPath. The report shows how communities and banks can help young people manage their own bank accounts.

DFPI Crackdown on Crypto Kiosk Operators

We issued a press release announcing an enforcement action against crypto kiosk operator Coinhub for violations of the Digital Financial Assets Law (DFAL). Coinhub must pay $675K for breaking the law as the DFPI continues to crack down on bad actors in the cash-to-crypto kiosk industry. Learn more about crypto kiosk scams.

Safeguard Metals Enforcement Action

We announced an enforcement action against California-based Safeguard Metals and its owner, Jeffrey Santulan, for coercing elderly people to use their retirement savings to purchase overpriced metals and coins. The company will pay more than $51 million in restitution and penalties.

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

Pursuant 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^st.

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 pursuant 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.

Debt Settlement Registrants Providing Student Debt Relief Services Requires Separate Registration

Pursuant to California Code of Regulations (CCR) title 10, section 1021, if an applicant is offering or providing more than one financial product or service that requires registration under the California Consumer Financial Protection Law (CCFPL), a separate registration is required for each. If you are a Debt Settlement registrant under the CCFPL that also offers or provides student debt relief services, you must apply for the Student Debt Relief Services registration. California Code of Regulations, title 10, section 1002(e) defines “student debt relief services” as follows:

1. Any debt settlement service, as that term is defined by section 1001, subdivision (b), where the underlying debt is student debt; or
2. Any of the following acts performed in connection with, or in contemplation of, an attempt to secure a revised payment plan or schedule, forbearance, consolidation, or forgiveness, in connection with student debt:
   • Assessing suitability or providing advice;
   • Preparing documents to be submitted by a consumer or on the consumer’s behalf; or
   • Acting as an intermediary between a consumer and the servicer of the consumer’s student debt.

If this requirement applies to you, please submit your CCFPL Student Debt Relief Services registration application through the Nationwide Multistate Licensing System and Registry (NMLS) immediately. If this requirement does not apply to you, please provide a written statement confirming that you do not offer or provide student debt relief services that requires registration under the CCFPL via email to [email protected]. Please include your Legal Name and CCFPL Registration Number in your email.

For more information, please visit our California Consumer Financial Protection Law Information for New Registrants and Student Debt Relief Services webpages on the DFPI website.

If you have questions, please email us at [email protected].

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, pursuant to Financial Code section 100020. Failure to timely pay the annual assessment by the due date may result in penalties pursuant to Financial Code section 90012, subdivision (c) for any violation of up to $25,000 for each day and statutory penalties pursuant to Financial Code section 100020, subdivision (b). In addition, pursuant 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 pursuant 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.

Investment Adviser Representative Continuing Education (IAR CE) Hours Due Mid-November

The deadline for DFPI registered investment adviser representatives to complete the required IAR CE (Investment Adviser Representative Continuing Education) hours for 2024 is quickly approaching. Any IARs with required IAR CE hours for 2024 that have not been fully completed will be unable to renew their registration for 2026. The DFPI recommends completing all CE hours due for by mid-November to allow time for the credits to be reported before the annual FINRA system shutdown on December 26, 2025.

For more information about IAR CE program, please visit the DFPI website.

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.

Where Compliance Meets the Coastline Event

Under the direction of Sheila R. Oliver, Deputy Commissioner, Escrow and Mortgage Lending Office, Ann Vo, CRMLA Portfolio Manager and Sean Shahlori, CRMLA Examination Manager spearheaded training on accounting and cybersecurity at a RegList Compliance Conference on November 4 in Huntington Beach.

They joined top compliance, legal, and risk professionals at a two-day event focused on emerging regulatory trends and practical compliance strategies. The conference featured in-depth sessions on market updates, recent exam findings, cybersecurity, AI and data use in compliance management systems, and validation practices. Attendees included compliance executives, legal partners, regulators, and industry consultants from across the mortgage and financial sectors.

Upcoming Consumer Education Event

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

Protect Yourself from Holiday Scams Webinar

Nov. 12, 12 – 1 p.m.

Don’t let scammers ruin your holidays! Learn how to stay safe and secure during the holiday season with information on the most common charity, shopping, payment, and online scams.

Register here.