Monthly Bulletin – June 2025

Senior Deputy Commissioner Appointment

On May 21, Governor Newsom appointed Armen Meyer as DFPI’s Senior Deputy Commissioner of Consumer Financial Protection. Meyer will oversee the DFPI’s newer oversight functions related to emerging fintech products, debt collectors, student loan companies, and digital financial assets. He will be sworn in to his position in July.

2024 CCFPL Activities

We announced the 2024 Annual Report on the California Consumer Financial Protection Law (CCFPL) highlighting increases in investigations, enforcement actions, and consumer outreach under one of the nation’s most comprehensive consumer financial protections laws.

Notice of Proposed Rulemaking – Money Transmission Act – Comments Due July 15, 2025

The Commissioner of the Department of Financial Protection and Innovation proposes to amend California Code of Regulations, Title 10, Sections 80.4119 and 80.5200.1 as set forth in the documents below. The proposed action would amend the officer certification requirement for money transmission receipts. The Commissioner will consider all comments, objections, and recommendations regarding the proposed action.

• Notice of Proposed Action – Notice of Proposed Action (PDF)
• Text of Proposed Regulations – Text of Proposed Regulations (PDF)
• Initial Statement of Reasons – Initial Statement of Reasons (PDF)

TIME FOR COMMENTS

The Commissioner invites interested parties to submit comments by July 15, 2025.

Submit comments by any of the following methods:

• By email to: [email protected]. Please include “PRO 05-24” 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

Advisory to Small Businesses: Speak Up About Merchant Cash Advances

Are you a business owner who might’ve been misled or kept in the dark about the terms of a merchant cash advance (MCA) or other commercial financing product? If you’ve experienced deception, abuse, or unfair treatment through a MCA or similar product, we want to hear from you. Read our Consumer Alert.

Broker-Dealer and Investment Adviser (BDIA) Division Updates

Introducing BDIA Finders Portal

Finders who satisfies all of the conditions set forth in Corporations Code section 25206.1, shall be exempt from the provisions of Section 25210. Effective May 27, 2025, a finder exemption may be filed with the DFPI directly on the new BDIA Finders Portal.

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

BDIA Investment Adviser Representative Continuing Education (IAR CE) – FinPro account set up

The continuing education (CE) requirement for investment adviser representatives (IARs) of both state-registered and SEC-registered investment advisers became effective in California in 2024. The IAR CE regulation requires that IARs complete twelve credits of continuing education annually, with six credits focused on Products and Practice and six credits focused on Ethics and Professional Responsibility. An overview of IAR CE requirements can be found on the North American Securities Administrators Association (NASAA) website and an Introduction to IAR CE course is available that explains the program.

It is recommended that IARs create a Financial Professional Gateway (FinPro) account in order to track their CE progress. The account provides representatives direct access to the tools and resources to manage their own securities registration information, gives them the ability to monitor their CE requirement progress, and allows FINRA the ability to reach them with notifications related to their industry records and requirements.

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

Escrow News

2025-26 Annual Assessment

The 2025-26 annual assessment invoices were issued and mailed to licensees under the Escrow law on May 29, 2025. The annual assessment is due within 30 days upon receipt of the invoice.

Financial Code section 17207 (e)(1) authorizes the Commissioner of Financial Protection and Innovation to levy an annual assessment for the support of this division for the ensuring year not to exceed $2,800 for each location.

If an escrow agent fails to pay the annual assessment within 30 days, the commissioner may assess a penalty of 10 percent of the annual assessment for each month or part of a month that the payment is delayed. Also, the commissioner may by order summarily suspend or revoke the escrow agent’s license. Licensees are encouraged to budget appropriately for this upcoming expenditure.

Some Escrow Annual Reports Due June 13

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 February 28, 2025, your annual report is due June 13, 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

The Escrow Advisory Committee currently has an open position for a representative of small-sized escrow companies.

In addition, three more positions will become available after August 2025:

• A representative for escrow companies with a business specialization
• A representative for medium-sized escrow companies
• An attorney

The Committee is established under Financial Code Section 17214. Its purpose, as set forth in statute, is to assist the Commissioner in carrying out responsibilities under the Escrow Law. The Committee consists of eleven members, including the Commissioner or the Commissioner’s designee. Committee members, other than those representing the Escrow Institute of California and the Escrow Agents’ Fidelity Corporation, are appointed by the Commissioner. The Committee meets at least once each quarter at the Department’s office.

Qualified individuals are encouraged to apply by submitting a letter of qualification and a resume to:

Paul Liang
Assistant Deputy Commissioner
320 West 4th Street, Suite 750
Los Angeles, California 90013

Submission Deadline: July 10, 2025

For questions or additional information, please contact Paul Liang at (213) 576-7535 or [email protected].

California Deferred Deposit Transaction Law (CDDTL) News

Notice to CDDTL Licensees about Increased Assessment

Per Financial Code Section 23016, licensees are required to pay the commissioner their pro rata share of the costs to administer the CDDTL program which will be due by June 30, 2025.  In addition, there has been a change to the methodology for how the assessments are calculated. California Assembly Bill 3148 changed the fee structure from a per location to a pro rata based on total dollar amount of deferred deposit transactions per licensee effective January 1, 2025. Thus, each licensee will pay their pro rata share of their total dollar amount of DDTs made as it bears to the aggregate of the total dollar amount of deferred deposit transactions made by all licensees.  There may be a change to your assessment amount due to the new methodology.

DFPI will mail invoices to all licensees by May 20, 2025. Invoices must be paid within 30 days, with an additional week allowed for payments made via electronic funds transfers (EFT).

If you need assistance with your assessment payment, please email [email protected] and a DFPI representative will contact you.

Money Transmitter News

PRO 05-24 – Notice of Proposed Rulemaking – Money Transmission Act – Comments Due July 15, 2025

The Commissioner of the Department of Financial Protection and Innovation proposes to amend California Code of Regulations, Title 10, Sections 80.4119 and 80.5200.1 as set forth in the documents below. The proposed action would amend the officer certification requirement for money transmission receipts. The Commissioner will consider all comments, objections, and recommendations regarding the proposed action.

• Notice of Proposed Action – Notice of Proposed Action (PDF)
• Text of Proposed Regulations – Text of Proposed Regulations (PDF)

Initial Statement of Reasons – Initial Statement of Reasons (PDF)

TIME FOR COMMENTS

The Commissioner invites interested parties to submit comments by July 15, 2025.

Submit comments by any of the following methods:

• By email to: [email protected]. Please include “PRO 05-24” 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

Email Spoofing Incident

The California Department of Financial Protection and Innovation (DFPI) has received reports of a fraudulent email being sent from an imposter spoofing the DFPI’s consumer service email ([email protected]) and claiming that the DFPI’s Securities Regulation Division has implemented a new quarterly reporting form. The Securities Regulation Division has NOT implemented a new quarterly reporting form for Investment Advisers. Do not access the link provided within the body of the email and do not provide any personal information.

For your information, the content of the fraudulent email is as follows:

Subject: New Reporting Form

Effective May 2025, the California Department of Financial Protection and Innovation, Securities Regulation Division, has implemented a new quarterly reporting form for Investment Advisors under the California Corporate Securities Law of 1968. To download the new form and its submission guidelines, please use this link: New Quarterly Reporting Form.pdf

Licensees and consumers should be extremely cautious when responding to messages or clicking on links in emails that seem suspicious. If you have clicked on the link in the email, you should take steps to protect your system and data, such as seeking the assistance of your IT professional on what to do when you have clicked on a potentially malicious link. If you have any questions, please reach out to your DFPI contact or call (866) 275-2677.

Checks sent to Prehired victims following pressure from DFPI

We that the Consumer Financial Protection Bureau (CFPB) is providing $4.2 million in long-delayed restitution to victims of a predatory tech sales program operated by Prehired, LLC after DFPI and several other states pressed for answers.

Industry News

Student Loan Debt Relief Scam Operators Agree to be Permanently Banned from Industry

The operators of an alleged transnational student loan debt relief scam have agreed to be permanently banned from the debt relief industry and to turn over more than $1 million in assets to resolve Federal Trade Commission charges that the operation bilked millions out of struggling student loan borrowers. More.

NASAA Urges Congress to Work with States to Foster Innovation and Mitigate Fraud

State securities regulators urge Congress to make important changes to the Digital Asset Market Clarity Act (CLARITY Act) to protect investors and promote responsible innovation. In a letter to the leadership of the U.S. House Committee on Financial Services and U.S. House Committee on Agriculture, the North American Securities Administrators Association (NASAA) explained that without changes to the CLARITY Act’s provisions governing the oversight of intermediaries offering and selling digital assets, investors stand to lose important protections provided by state securities regulators. More.

Upcoming Consumer Education Event

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

Protect Yourself from Identity Theft webinar

July 9, 10 – 11:00 a.m. | Virtual

Learn about the many ways criminals steal personal information and the steps you can take to safeguard your identity. Topics include common tactics, best practices for online security, how to monitor your credit, and how to recover if you become a victim. DFPI hosts in partnership with Asm. Cottie Petrie-Norris (AD73).

LICENSEE ACTIVITY

Bank Activity

Acquisition of Control

Robert Setrakian, to acquire control of Golden State Bank

Filed: 5/28/25

Merger

HomeStreet Bank, Seattle, Washington, to merge with and into Mechanics Bank, Walnut Creek, California
Filed: 5/01/25

Credit Union Activity

Merger

California Coast Credit Union, San Diego, to merge with and into San Diego County Credit Union, San Diego, with the surviving credit union to change its name to California Coast Credit Union
Filed: 5/23/25

Members 1^st Credit Union, Redding, California, to merge with and into Rogue Credit Union, Medford, Oregon
Filed: 5/16/25

Conversion

Arrowhead Central Credit Union, Rancho Cucamonga, to convert to federal charter
Effected: 4/01/25

California Credit Union, Glendale, to convert to federal charter
Filed: 4/02/25

Trust Company Activity

New Trust Company

Santa Barbara Trust Company
100 E. De La Guerra Street, Santa Barbara
Approved: 5/07/25

Change of Name

Enterprise Trust & Investment Company to change its name to Enterprise Trust Company

Effected: 4/09/25

Erratum

It was erroneously reported in the February 2025 issue that the approval date of Parallel Trust Company of California (In Organization) was 2/11/25. The correct approval date is 5/02/25.

Foreign (Other State) Bank Activity

New Office

Independent Trust Company, LLC
3250 Grey Hawk Ct., Carlsbad (Facility – non-insured)
Opened: 2/01/24

Money Transmitter Activity

New Money Transmitter

Digital Wallet US LLC
Approved: 5/16/25

Inmar Services LLC
Approved: 5/08/25

Klarna Inc.
Approved: 5/12/25

PayNearMe Financial, Inc.
Opened: 5/21/25