How to Fill Out California DFPI Property Assessed Clean Energy Administrator + FAQs

The California Department of Financial Protection and Innovation (DFPI) Property Assessed Clean Energy (PACE) Program Administrator Application is the licensing form every company that wants to administer residential PACE financing in California must file with the DFPI under the California Financing Law. The form authorizes a business to enroll public agencies, train solicitors, and approve PACE assessment contracts that attach a tax lien to a homeowner’s property under Streets and Highways Code §5898.20.

Filing this application correctly is high-stakes because a single wrong answer about ownership, bond amount, or program agreements can delay licensure by 90 to 180 days, and the DFPI reports that roughly 1 in 3 PACE administrator filings receive a deficiency letter on first review according to the agency’s own annual PACE report. This guide walks you through every box, attachment, and signature so your file moves through the DFPI Self-Service Portal (DOCQNET) without a kickback.

Here is what you will learn in this guide:

• 📋 How to prepare every required attachment before you open the application
• 🏛️ The exact statutes, fees, and bond amounts that govern PACE administrator licensure
• ✍️ A line-by-line walkthrough of each field on the application
• 👥 Three real-world scenarios showing what new entrants, existing licensees, and out-of-state fintechs enter
• ⚠️ The 10 most common mistakes that trigger DFPI deficiency letters and how to avoid them

What the Form Is and Who Must File It

The PACE Program Administrator Application is the single licensing instrument the DFPI uses to authorize a business under Financial Code §§22680–22692. Any company that administers residential PACE financing on behalf of a public agency must hold this license before it solicits a single homeowner. The form was created after AB 1284 (2017) and SB 242 (2017) shifted PACE oversight from local Joint Powers Authorities to a single state regulator.

You must file the application if your company performs any of the following functions for a sponsoring public agency: enrolls and trains solicitors, runs the ability-to-pay review, recommends approval of assessment contracts, or oversees the recording of PACE liens. Independent contractors who only install solar panels or HVAC units do not file this form, but the company that funds and administers their PACE contracts does. Companies like Renew Financial and successor administrators of HERO, CaliforniaFIRST, and Ygrene programs all hold this license.

Filing without a license is a violation of Financial Code §22713 and can trigger civil penalties up to $2,500 per violation plus disgorgement of fees collected. The DFPI also coordinates with the federal Consumer Financial Protection Bureau on PACE oversight under the 2018 amendment to the Truth in Lending Act, so federal liability layers on top of state penalties. The current version of the application carries a revision date of January 2024, which you can verify on the DFPI PACE forms page before downloading.

Before You Start: Documents and Information You Need

Gather every document below before you open the DOCQNET portal because the system times out after 30 minutes of inactivity and partially saved applications often lose attachments. The DFPI’s PACE application instructions PDF lists the full document checklist, but the items below are the ones that most often trip up first-time filers.

• Articles of Incorporation or Organization filed with the California Secretary of State — without these, the DFPI cannot verify your legal existence and the file is rejected immediately.
• Audited financial statements for the last fiscal year prepared under GAAP — unaudited statements are only accepted for newly formed entities under 10 CCR §1422.
• Surety bond of at least $25,000 issued by a California-admitted surety, with the bond rider naming the DFPI Commissioner as obligee.
• Organizational chart showing every parent, subsidiary, and affiliate down to a 10% ownership level.
• Sample PACE assessment contract matching the form approved under Streets and Highways Code §5898.17.
• Ability-to-pay policies and procedures that comply with Financial Code §22687 — missing this triggers an automatic deficiency.
• Oral confirmation of key terms script in English and Spanish, since Financial Code §22686 requires recorded confirmation before signing.
• Solicitor training program materials covering disclosures, prohibited practices, and elder abuse red flags.
• Program agreements with every sponsoring public agency or Joint Powers Authority you plan to serve.
• Live Scan fingerprint receipts (Form BCIA 8016) for every executive officer and 10%+ owner.
• NMLS MU1 (company) and MU2 (individual) filings completed in the Nationwide Multistate Licensing System.

Each item ties to a specific statutory requirement, and missing any one of them stops the review clock until you cure the defect.

Where to Get the Form and How to Access It

The official application lives on the DFPI PACE Program Administrator page as a fillable PDF, but the actual submission happens inside the DOCQNET Self-Service Portal. You first download the PDF to confirm field labels and required attachments, then re-enter the data into DOCQNET because the portal does not accept the PDF as the primary filing.

Create a DOCQNET account using a corporate email address rather than a personal Gmail because the DFPI sends deficiency letters and license certificates only to the registered email. After registering, link your NMLS company record using the company’s NMLS ID, which you can look up in the NMLS Consumer Access database. The portal will pull your MU1 disclosures automatically once linked.

If you prefer paper, the DFPI still accepts mailed applications at Department of Financial Protection and Innovation, 2101 Arena Boulevard, Sacramento, CA 95834, but processing time runs 30 to 60 days longer than online filings according to the agency’s published licensing turnaround data. Fax filings are not accepted for PACE administrator applications. In-person drop-off is available at the Sacramento and Los Angeles DFPI offices, but staff will not review the file at the counter.

Step-by-Step: How to Fill Out the PACE Program Administrator Application Line by Line

The application is divided into nine parts. Each part below gets its own H3 walkthrough with the six required elements: plain-English explanation, how to answer, a named example entry, an edge case, a common mistake with consequence, and a misconception correction.

Part 1, Box 1: Legal Name of Applicant

This box asks for the exact legal name of the company as it appears on the Articles of Incorporation or Organization filed with the California Secretary of State. The DFPI cross-references this name against the Secretary of State’s database, so even a missing comma or “Inc.” abbreviation will flag the file.

To answer, type the name in mixed case exactly as recorded, including punctuation and entity suffixes such as “LLC” or “Inc.” Do not abbreviate “California” to “CA” inside the entity name unless the official record does. The portal accepts up to 200 characters in this field.

For example, Maria Lopez, the compliance officer at a new PACE administrator, enters GreenLien Capital Administrators, Inc. exactly as it appears on the company’s Articles of Incorporation.

If your company recently changed its name, file a Statement of Information with the Secretary of State first and wait for the updated record to post before submitting the DFPI application. The DFPI will not accept a “name change pending” notation in this box.

The most common mistake is using a DBA or trade name in Box 1 instead of the legal entity name. The direct consequence is an automatic deficiency letter and a 30-day pause while the applicant refiles.

A frequent misconception is that the DFPI license can be issued under a fictitious business name. It cannot — the license attaches to the legal entity, and DBAs go in Box 2.

Part 1, Box 2: Fictitious Business Names (DBAs)

Box 2 captures every DBA, trade name, or assumed name your company uses in California. The DFPI publishes these on the licensee search page so consumers can verify a solicitor’s affiliation.

Enter each DBA on its own line, exactly as registered with the county clerk under Business and Professions Code §17910. Attach a copy of the Fictitious Business Name Statement for each one as a supporting document.

For example, GreenLien Capital Administrators, Inc. enters GreenLien PACE and EcoAssess California on separate lines because both names appear on its solicitor scripts.

If a DBA is registered in only one California county but solicitors operate statewide, you must register the DBA in every county where solicitations occur. Single-county registration is a frequent enforcement target for the DFPI.

The most common mistake is omitting a DBA that appears in marketing materials but not on contracts. The consequence is a Financial Code §22161 violation for misleading advertising, with fines up to $2,500 per ad.

A common misconception is that out-of-state DBAs do not need to be listed. They do, if the DBA appears anywhere a California consumer might see it.

Part 1, Box 3: NMLS Unique Identifier

Box 3 captures your company’s NMLS ID, which the DFPI uses to pull MU1 disclosures automatically. Every PACE administrator must register in NMLS under the DFPI’s adoption of the Multistate Licensing Compact.

Enter the seven-digit NMLS ID exactly as displayed in your NMLS company record. Do not include hyphens, spaces, or the letters “NMLS.” If you do not yet have an NMLS ID, create the company record first at NMLS company registration before starting the DFPI application.

For example, GreenLien Capital Administrators, Inc. enters 2456789 in Box 3.

If your company holds NMLS records in multiple states, the DFPI still uses the same single NMLS ID. Do not create a separate California-only NMLS record.

The most common mistake is entering the individual MU2 number of an officer instead of the company MU1 number. The consequence is a deficiency letter and possible delay of fingerprint matching.

A frequent misconception is that NMLS registration alone is the license. It is not — NMLS is the data backbone, but the actual authority to administer PACE comes from the DFPI license.

Part 2: Business Structure and Ownership Disclosures

Part 2 asks about the entity type, state of formation, and every owner who holds 10% or more of voting equity. The DFPI uses this to run Financial Code §22682 suitability checks on each disclosed person.

Check the box for entity type (Corporation, LLC, Limited Partnership, or Other), enter the state of formation, and then list every direct and indirect 10%+ owner with their full legal name, date of birth, Social Security number, and percentage owned. Use the supplemental Form 22154 if you have more than five owners.

For example, Marcus Chen, CEO of a fintech expanding into California, lists himself at 32%, his co-founder Aisha Patel at 28%, and the venture fund Sequoia Climate III, L.P. at 25%, with the fund’s general partners disclosed on a continuation page.

For trust ownership, disclose the trustee, every beneficiary with a vested 10%+ interest, and the trust’s tax ID. The DFPI treats revocable trusts as transparent for ownership purposes.

The most common mistake is omitting indirect ownership through a parent holding company. The consequence is a finding of incomplete disclosure under Financial Code §22101.5, which can trigger license denial.

A common misconception is that minority owners under 10% never need to be disclosed. They do, if they hold a control position such as a board seat or veto right.

Part 3: Executive Officers and Control Persons

This part asks for every executive officer, director, manager, and control person, defined under 10 CCR §1422.5 as anyone with the power to direct management. Each person must complete an MU2 individual filing in NMLS and submit Live Scan fingerprints.

Enter each person’s full legal name, title, NMLS individual ID, date of hire, and a yes/no answer to the seven background questions about felonies, financial-services misconduct, and prior license actions. Attach a resume covering the last 10 years of employment with no gaps longer than 30 days.

For example, Janet Rivera, Chief Compliance Officer at GreenLien, enters her name, title, NMLS ID 3456789, hire date 03/15/2024, and answers No to all seven background questions, with her resume attached as a separate PDF.

If an officer answers Yes to any background question, attach a written explanation, the charging document, the disposition, and a character reference letter. The DFPI does not automatically deny based on a Yes answer, but undisclosed Yes answers found in fingerprint results result in immediate denial.

The most common mistake is treating a non-employee board observer as exempt from disclosure. The consequence is a control-person violation and a $1,000 to $5,000 administrative fine.

A frequent misconception is that officers of the parent company do not count. They do, if the parent exercises control over PACE operations.

Part 4: Surety Bond

Part 4 captures the surety bond required by Financial Code §22683. The minimum bond is $25,000, but the DFPI may require up to $200,000 based on the volume of PACE assessments funded.

Enter the surety company name, the surety’s California Department of Insurance certificate number, the bond number, the effective date, and the bond amount. Attach the original bond rider with the corporate seal and notarization.

For example, GreenLien Capital Administrators, Inc. enters surety Travelers Casualty and Surety Company of America, certificate 3585-3, bond number 107295678, effective 01/01/2026, amount $100,000 based on its projected $50 million annual PACE volume.

If your projected volume exceeds $100 million annually, the DFPI will likely require a $200,000 bond and may also impose net-worth conditions. Plan for the higher amount during financial planning.

The most common mistake is filing a bond from a surety not admitted in California. The consequence is rejection of the bond and a 60-day window to refile with an admitted surety, during which the application is paused.

A common misconception is that the bond can be replaced with a cash deposit. It can, but only with prior DFPI approval and a deposit account at a California-chartered bank.

Part 5: Financial Statements

Part 5 requires audited GAAP financial statements for the most recent fiscal year. Newly formed entities under one year old may submit unaudited statements with a CPA compilation letter under 10 CCR §1422.

Upload the balance sheet, income statement, statement of cash flows, and notes as a single PDF. The DFPI checks for minimum tangible net worth of $250,000 and a positive working capital position.

For example, Aisha Patel, CFO of a fintech entrant, uploads the company’s 2025 audited statements showing $3.2 million tangible net worth and $1.8 million working capital, well above the minimums.

If your fiscal year ends within 90 days of filing, you may submit prior-year audited statements plus interim unaudited statements. After 90 days, the audit must be current.

The most common mistake is submitting tax returns instead of GAAP financials. The consequence is automatic deficiency and a 30-day cure window.

A common misconception is that consolidated parent financials are sufficient. They are not — the applicant entity’s standalone financials are required, even if consolidated statements are also provided.

Part 6: Program Agreements and Sponsoring Public Agencies

This part lists every public agency or Joint Powers Authority that has approved your company to administer PACE within its jurisdiction. The agreement must comply with Streets and Highways Code §5898.20.

For each agency, enter the agency name, the date of the program agreement, the geographic territory covered, and attach an executed copy of the agreement. List at least one agreement, since the DFPI does not issue a license to administer PACE in a vacuum.

For example, GreenLien Capital Administrators, Inc. lists the California Statewide Communities Development Authority (CSCDA), agreement dated 11/15/2025, territory all participating CSCDA member counties, with the executed agreement attached.

If you plan to serve a successor JPA to HERO or Ygrene, attach the assignment-and-assumption agreement showing the chain of authority from the original JPA. Missing assignment documents is a frequent kickback reason.

The most common mistake is attaching a draft or unsigned program agreement. The consequence is rejection of the application until a fully executed agreement is filed.

A common misconception is that a single statewide JPA agreement covers every California county. It does not — verify the JPA’s member list and disclose any non-member counties separately.

Part 7: Policies, Procedures, and Training Materials

Part 7 attaches the operational backbone of your PACE program: ability-to-pay policy, oral confirmation script, solicitor training curriculum, complaint handling procedure, and the prohibited-practices acknowledgment required by Financial Code §22689.

Upload each document as a separate PDF with a clear filename such as AbilityToPayPolicy_v3_2026.pdf. Confirm that the oral confirmation script captures all key terms enumerated in Financial Code §22686, including total cost, APR-equivalent, and impact on property tax payments.

For example, Janet Rivera, the CCO, uploads seven separate PDFs covering each policy area, each labeled with the policy version and effective date.

If your training curriculum is delivered through an online learning management system, attach the course outline plus a sample completion certificate. The DFPI does not accept “see our LMS” as a substitute for written materials.

The most common mistake is submitting a generic policy template without California-specific provisions. The consequence is a deficiency letter and rejection until customized policies are filed.

A common misconception is that elder abuse training is optional. It is required by Welfare and Institutions Code §15630 for every solicitor.

Part 8: Application Fee and Payment

Part 8 captures the $2,400 nonrefundable application fee set by Financial Code §22680.5. Pay through the DOCQNET portal using ACH, credit card, or wire transfer.

Enter the payment method, transaction confirmation number, and date of payment. Save the receipt — the DFPI will not start review until payment clears, typically two business days for ACH and same-day for credit card.

For example, Marcus Chen pays the $2,400 fee by ACH on 02/03/2026 and enters confirmation number DOCQ-2026020300457 in the payment box.

If your application is later withdrawn or denied, the $2,400 fee is not refunded under 10 CCR §1422.6. Plan to file only when your file is complete.

The most common mistake is paying by personal credit card from an officer’s account. The consequence is a delay while the DFPI verifies that the corporate entity, not the individual, is the actual filer.

A common misconception is that paying the fee guarantees license issuance. It does not — the fee covers review costs only, regardless of outcome.

Part 9: Certification and Signature

The final part is a sworn certification under penalty of perjury that every statement and attachment is true and complete. The signing officer must be a duly authorized executive officer with corporate authority to bind the applicant.

Enter the signer’s full legal name, title, date, and digital signature in DOCQNET. The portal uses Adobe-compliant e-signatures that meet Civil Code §1633.7 standards.

For example, Marcus Chen, CEO, signs as Marcus Chen, Chief Executive Officer with date 02/03/2026.

If the signing officer is not separately disclosed in Part 3, the application is automatically rejected because the DFPI cannot verify signing authority. Always confirm the signer is also listed as an officer.

The most common mistake is having a non-officer attorney sign on the company’s behalf. The consequence is rejection and a 30-day cure period.

A common misconception is that an electronic signature carries less weight than ink. It does not — e-signatures in DOCQNET have the same legal effect as wet signatures under Civil Code §1633.7.

Three Filled-Out Examples Using Real Scenarios

The three scenarios below show how different filers complete the same application. Each named person represents one of the most common applicant profiles based on DFPI’s PACE licensee roster.

Scenario 1: New Entrant — GreenLien Capital Administrators, Inc.

GreenLien is a brand-new California corporation formed in late 2025 with $5 million in seed capital and one executed JPA agreement with CSCDA.

Form Section	What GreenLien Enters
Box 1: Legal Name	GreenLien Capital Administrators, Inc.
Box 2: DBAs	GreenLien PACE, EcoAssess California
Box 3: NMLS ID	2456789
Part 2: Entity Type	Corporation, California, formed 09/12/2025
Part 3: CEO	Marcus Chen, NMLS 3456788
Part 4: Surety Bond	$100,000, Travelers, bond #107295678
Part 5: Financials	Unaudited 2025 + CPA compilation letter
Part 6: Program Agreements	CSCDA, dated 11/15/2025
Part 8: Fee	$2,400 ACH, paid 02/03/2026
Part 9: Signature	Marcus Chen, CEO, 02/03/2026

Scenario 2: Existing CFL Licensee Adding PACE — Pacific Lending Corp.

Pacific Lending already holds a California Financing Law license and wants to add PACE administrator authority without forming a new entity.

Form Section	What Pacific Lending Enters
Box 1: Legal Name	Pacific Lending Corp.
Box 2: DBAs	Pacific PACE Solutions
Box 3: NMLS ID	1123456
Part 2: Entity Type	Corporation, Delaware, qualified in California
Part 3: Officers	Janet Rivera, CCO; David Park, CEO
Part 4: Surety Bond	$200,000 rider added to existing CFL bond
Part 5: Financials	2025 audited GAAP statements, $42M net worth
Part 6: Program Agreements	CSCDA + Golden State Finance Authority
Part 8: Fee	$2,400 wire, paid 01/20/2026
Part 9: Signature	David Park, CEO, 01/20/2026

Scenario 3: Out-of-State Fintech — Helios Climate Finance, LLC

Helios is a Delaware LLC headquartered in Austin that wants to expand into California PACE financing.

Form Section	What Helios Enters
Box 1: Legal Name	Helios Climate Finance, LLC
Box 2: DBAs	Helios PACE
Box 3: NMLS ID	3456123
Part 2: Entity Type	LLC, Delaware, qualified in California 12/01/2025
Part 3: Officers	Aisha Patel, Manager; Marcus Chen, Manager
Part 4: Surety Bond	$50,000, Liberty Mutual, bond #LM-558290
Part 5: Financials	2025 audited GAAP, $8.4M net worth
Part 6: Program Agreements	CSCDA pending; California HERO assignment attached
Part 8: Fee	$2,400 credit card, paid 02/15/2026
Part 9: Signature	Aisha Patel, Authorized Manager, 02/15/2026

How to File the Completed Form

Once every part is complete and every attachment is uploaded, you submit through one of three channels. Each channel has its own URL or address, fee handling, processing time, and proof-of-filing protocol.

Online via DOCQNET is the preferred channel. Log into the DFPI Self-Service Portal, click Submit Application, and pay the $2,400 fee by ACH, credit card, or wire. ACH posts in two business days, credit card same day, wire same day. After submission, save the PDF receipt and confirmation email — these are your proof-of-filing. Average processing time is 90 to 120 days based on the DFPI licensing dashboard.

By mail to Department of Financial Protection and Innovation, Attn: PACE Licensing, 2101 Arena Boulevard, Sacramento, CA 95834. Pay the fee by certified check or cashier’s check made out to Department of Financial Protection and Innovation. Send the package by certified mail with return receipt requested, and keep the green card as your proof-of-filing. Processing time runs 150 to 180 days.

In person at the Sacramento headquarters or the Los Angeles regional office at 320 West Fourth Street, Suite 750, Los Angeles, CA 90013. Pay by certified check; cash is not accepted. Counter staff stamp a copy of the cover letter as your proof-of-filing, but no substantive review happens at the counter. Processing time matches mail filings.

Fax filings are not accepted for PACE administrator applications under any channel.

What Happens After You File

After submission, the DFPI assigns a license analyst within 10 business days and sends an acknowledgment letter through DOCQNET. The analyst’s name and direct email become your point of contact for the rest of the review.

The first substantive review happens 30 to 45 days after submission and produces either a clearance memo or a deficiency letter. Deficiency letters list each missing or incorrect item with a 30-day cure window under 10 CCR §1422.7. If you cure within the window, the clock keeps running; if you miss it, the application is deemed withdrawn and the fee is forfeited.

Once the file is clean, the DFPI issues a conditional approval pending fingerprint clearance from the California Department of Justice. Final license issuance follows within 14 days of fingerprint clearance, and the license number posts to the public DFPI licensee search. You may not begin soliciting California homeowners until the license number posts.

Mistakes to Avoid When Filling Out the Form

Each mistake below is drawn from DFPI deficiency-letter patterns reported in the agency’s annual PACE report.

• Using a DBA instead of the legal name in Box 1. Consequence: automatic 30-day deficiency.
• Omitting indirect 10%+ owners through a parent. Consequence: incomplete-disclosure finding under §22101.5.
• Filing a surety bond from a non-California-admitted surety. Consequence: bond rejection and 60-day cure period.
• Submitting tax returns instead of GAAP financials. Consequence: financial-statement deficiency.
• Attaching draft or unsigned program agreements. Consequence: rejection until executed agreements are filed.
• Skipping the Spanish-language oral confirmation script. Consequence: deficiency under §22686.
• Having a non-officer attorney sign Part 9. Consequence: rejection and 30-day cure.
• Forgetting Live Scan for a control person. Consequence: indefinite delay until fingerprints are submitted.
• Paying the application fee from a personal account. Consequence: payment verification delay.
• Listing a DBA registered in only one county for statewide use. Consequence: misleading-advertising violation under §22161.
• Using consolidated parent financials without standalone applicant financials. Consequence: financial-statement deficiency.
• Failing to disclose a board observer with veto rights. Consequence: control-person violation and possible denial.

Do’s and Don’ts

The points below distill the DFPI’s published licensing best practices into actionable rules.

• Do verify your legal name against the Secretary of State record before opening Box 1, because mismatches stop review.
• Do complete NMLS MU1 and MU2 filings before starting DOCQNET, because the portal pulls from NMLS automatically.
• Do order Live Scan fingerprints early, because DOJ turnaround can run 30 days.
• Do schedule a CPA audit at least 90 days before filing, because audit timing is the most common bottleneck.
• Do save every DOCQNET confirmation email, because they are your proof-of-filing.
• Do assign one internal point of contact for the DFPI analyst, because consistent communication speeds review.
• Don’t rely on draft program agreements, because the DFPI rejects them on sight.
• Don’t abbreviate field entries, because DOCQNET cross-references exact text.
• Don’t skip Spanish-language materials, because they are required under §22686.
• Don’t assume tax returns count as financials, because GAAP audits are required.
• Don’t let an officer answer No to background questions without checking criminal records, because undisclosed Yes answers cause denial.
• Don’t start soliciting before the license number posts, because pre-license activity violates §22713.

Pros and Cons of Filing on Your Own vs. With Help

Many applicants weigh whether to file pro se or hire a licensing consultant or California-licensed attorney. The points below frame the trade-offs.

Pros of filing on your own:

• Lower upfront cost, since consultant fees often run $25,000 to $75,000.
• Direct knowledge of internal operations, which speeds answering officer-disclosure questions.
• Faster internal turnaround when DFPI deficiency letters arrive, because no third-party loop is involved.
• Builds in-house compliance expertise that pays dividends during examinations under §22701.
• Direct relationship with the DFPI analyst, which can become valuable for future filings.

Cons of filing on your own:

• Higher risk of deficiency letters that add 30 to 90 days per round.
• Steeper learning curve on statutes such as Streets and Highways Code §5898.17.
• Time cost for senior officers, who must sign certifications personally.
• Risk of mis-drafted policies that trigger consumer harm later, exposing the company to enforcement.
• No professional malpractice coverage if mistakes lead to license denial.

FAQs

Is the $2,400 application fee refundable if my application is denied?

No. The fee is nonrefundable under 10 CCR §1422.6 regardless of outcome, so file only when your package is complete and every attachment is finalized.

Do I need a separate license for each public agency I serve?

No. One DFPI PACE administrator license covers every public agency in California, but you must file each program agreement separately under Part 6 of the application.

Can I write my DBA in Box 1 if it is more recognizable than my legal name?

No. Box 1 requires the exact legal name from your Articles of Incorporation, and DBAs go in Box 2 only.

Do I list officers of my parent company in Part 3?

Yes. If the parent exercises control over PACE operations, every parent officer who directs management is a control person and must be disclosed.

Is the minimum surety bond always $25,000?

No. $25,000 is the floor, but the DFPI scales the bond up to $200,000 based on projected PACE volume under §22683.

Can I submit unaudited financials if my company is brand new?

Yes. Entities under one year old may submit unaudited statements with a CPA compilation letter, but every subsequent year requires full GAAP audits.

Do I need to attach a Spanish oral confirmation script even if my solicitors only speak English?

Yes. Financial Code §22686 requires a Spanish version because California requires confirmation in the consumer’s primary language.

Can my licensing attorney sign Part 9 instead of an officer?

No. Only a duly authorized executive officer who is also disclosed in Part 3 may sign the certification under penalty of perjury.

Does my NMLS registration replace the DFPI license?

No. NMLS is the data system, and the DFPI license under §22680 is the actual operating authority.

Can I begin training solicitors before my license is issued?

Yes. Internal training is permitted before licensure, but no solicitor may contact a homeowner until the license number posts to the public DFPI search.

Do I need to disclose owners under 10% if they hold a board seat?

Yes. Anyone with a control position is disclosed regardless of ownership percentage under 10 CCR §1422.5.

Will the DFPI accept a draft program agreement while the final version is negotiated?

No. Only fully executed agreements satisfy Part 6, and drafts trigger automatic rejection.

Can I pay the application fee in cash at the Sacramento office?

No. Cash is not accepted at any DFPI office, and only certified checks, cashier’s checks, ACH, credit card, or wire transfers are valid payment methods.

How long after submission until I can start funding PACE assessments?

No activity may begin until the license posts, which typically takes 90 to 180 days after a clean submission depending on channel and fingerprint turnaround.