State Regulatory Developments

CA Adopts Proposed Regulations Under the Debt Collection Licensing Act

California recently adopted its “Proposed Regulations under the Debt Collection Licensing Act.”  Among other things, effective December 22, 2021, the Commissioner of Financial Protection and Innovation designated the NMLS to receive and store filings, obtain credit reports, and collect fees and assessments from applicants and licensees on behalf of the Commissioner.  The required use of the NMLS will apply towards all applications, amendments, surety bonds, notices, related filings, supporting documents, renewals, authorizations, assessments, and fees, except for those otherwise designated by statute.

In filings made through the NMLS, unless stated otherwise, a document is considered filed with the Commissioner when all fees are received and the filing is transmitted by the NMLS to the Commissioner.  Any document that is required to be filed with the Commissioner that cannot be filed with the NMLS must be filed directly with the Commissioner.