The California Department of Financial Protection and Innovation (DFPI) has released its 2026 annual assessment for debt collection licensees through the Nationwide Multistate Licensing System (NMLS). The annual assessment fee is due within 30 days of receipt of the invoice and failure to pay the annual assessment fee by Jan. 2, 2027, will result in a penalty assessed pursuant to California Financial Code section 100020(b). RMAI strongly recommends not waiting until the January 2nd date in case you experience challenges with transmission.

RMAI is encouraging its members who are licensed under the California Debt Collection Licensing Act (CA Fin Code § 100000 et seq.) to pay their annual licensing assessment to DFPI under protest. By sending a letter of protest, members are helping inform the DFPI about the unreasonable level of this fee. Members paying under protest may also help bolster our overall litigation and legislative strategies by providing documentation on the impact of regulatory fees.

The joint lawsuit — RMAI, ACA International and Progressive Management Systems v. California Department of Financial Protection and Innovation — filed in April 2026 — for unlawful licensing assessments remains ongoing.

Below is a sample protest letter you may use. Since correspondence cannot be submitted with your payment through NMLS, it is suggested that you mail the letter directly to the DFPI and/or email it:

Department of Financial Protection and Innovation

Attn: Debt Collection Licensing Program

651 Bannon Street, Suite 300

Sacramento, CA 95811

Email: [email protected]

RMAI encourages you to maintain copies of the protest letter you sent to DFPI.

Please note that this is not legal advice and RMAI encourages its members to consult with legal counsel prior to the submission of the letter.

SAMPLE PROTEST LETTER

[Insert Date]

Department of Financial Protection and Innovation

Attn: Debt Collection Licensing Program

651 Bannon Street, Suite 300

Sacramento, CA 95811

Re: Payment of License Assessment Under Protest – [Insert Licensee Name / License Number]

Dear Commissioner:

Pursuant to applicable law, including Article XIII, Section 32 of the California Constitution, this letter constitutes formal notice that [Insert Licensee Name] hereby tendered payment of its 2026 license assessment through the Nationwide Multistate Licensing System on [insert date] under protest.

This protest is made on the following grounds:

  • Failure to consult with Advisory Committee (Fin. Code § 100021). The Department has not properly consulted with or obtained advice from the Debt Collection Advisory Committee as contemplated by the Debt Collection Licensing Act (Fin. Code § 100000 et seq.), including with respect to determining and advising on the method and amount of annual assessments. The absence of consultation renders the assessment process procedurally defective and inconsistent with the statutory framework.
  • Failure to comply with Proposition 26 (Cal. Const., art. XIII C, § 1 et seq. & art. XIII A). The Department’s assessment constitutes a “tax” within the meaning of Proposition 26 because it was imposed to raise general revenue or to fund regulatory activities not reasonably related to the payor’s burden or benefit from the licensing program. The assessment violates Proposition 26’s procedural and substantive mandates.

Licensee hereby advises DFPI that its payment of the 2026 California Debt Collection Licensing annual license assessment through the NMLS payment system was made under protest and with a full reservation of rights. Payment of the assessment was made solely to avoid penalties, suspension, or revocation of licensure. This protest preserves all rights to challenge the legality or amount of the assessment, including through judicial action seeking refund or declaratory relief.

Accordingly, [Licensee Name] respectfully requests that DFPI record this payment as “paid under protest” and maintain this letter in its official files for the 2026 license assessment.

Thank you for your attention to this matter.

Very truly yours,

[Insert Licensee Name / License Number]

 

 

This Member Alert is intended for members of the Receivables Management Association International, is for informational purposes only, and is in no way intended to provide legal advice. Members are encouraged to consult with an attorney of their choice for legal advice concerning this matter.