On July 15, the California Department of Financial Protection and Innovation began accepting transition requests via the Nationwide Multistate Licensing System for those California Financing Law licensees not currently on the system.
According to an announcement posted on the DFPI’s website, transitioning is voluntary until related proposed amendments to the CFL regulations are adopted. However, it is anticipated that the transition deadline will remain December 31, 2021.
Transition checklists and NMLS forms
The relevant transition checklists can be found here. CFL licensees that are new to NMLS must create an account and complete e-forms for the company, its branches, and its key individuals (commonly referred to as the Form MU1, Form MU3, and Form MU2, respectively). All transitioning CFL licensees — whether new to NMLS or not — are required to submit specific information and documents via the system, including:
- California business activity information
- California registered agent information
- California qualifying individual information
- Disclosure question explanations and supporting documents*
- Management chart*
- Organizational chart*
- Business plan*
- Electronic surety bond (the conversion of the paper bond on file with the DFPI to an ESB must be initiated prior to submitting the transition request)
* Required only if not previously filed with the DFPI or if the version previously filed with the DFPI is no longer accurate
Start now (and other things to keep in mind)
Transitioning a license to NMLS can require a significant amount of time, effort, and coordination, especially for licensees that are new to the system. Therefore, we suggest kicking off the effort as soon as possible. Here are a few other important things to keep in mind:
- To avoid being charged a new application fee, licensees should enter their current license number (including any and all punctuation, capitalization, etc.) in the transition number field in NMLS
- Licensees can confirm license status and license numbers by using the DFPI’s licensee search
- The non-refundable NMLS processing fee to transition is $100 for the company license and $20 for each branch license
- If a key individual previously submitted fingerprints to the DFPI for a criminal background check, a new set of fingerprints from the individual is not required
- There is no need to transition a branch license if it has been surrendered or is otherwise inactive
For more information
In tandem with publishing the transition checklists, the DFPI published a 15-page FAQs document covering a host of topics related to the transition process — from how to complete specific sections of the Form MU1 to how to submit amendments. Transitioning CFL licensees will also find the NMLS guidance for transitioning an existing company license and transitioning an existing branch license helpful.
APPROVED can help
APPROVED has launched a dedicated resource center with news and information for California licensees, including a recording of our July 7 webcast that covered even more details regarding the CFL transition process and requirements. For assistance with preparing and submitting CFL license applications, transitions, amendments, and more, check in with APPROVED.