[Olderguy]

No you don't need a CA license. You can use a super broker. However, many lenders are not no longer doing loans in CA.

[OC Funder]

No you don't need a CA license. You can use a super broker. However, many lenders are not no longer doing loans in CA.

If the super broker were gathering PII and selling the terms I suppose that would be fine, but if you are doing those things I think the law would still view you as brokering the transaction.

[Olderguy]

If the super broker were gathering PII and selling the terms I suppose that would be fine, but if you are doing those things I think the law would still view you as brokering the transaction.

No that's not correct.

"Due to California’s strict requirements about when disclosures must be provided, you cannot provide written offer details (principal/advance amount and any rate/pricing/cost or total repayment/remittance amount) to a merchant and state that the offer is the only one presented by Credibly. Presentation of a single offer triggers the disclosures and a single offer has not been made by Credibly until you select one in the Offer Calculator. Until you have selected an offer and contracts have been generated and sent to the merchant, if you are providing offers in writing (including text message) you must communicate multiple Credibly offers to the merchant."

"Once you’ve selected an offer in the Offer Calculator for your California merchant, you will notice a new pop up window. You’ll have to click to confirm prior to sending/downloading the contract."

[OC Funder]

No that's not correct.

"Due to California’s strict requirements about when disclosures must be provided, you cannot provide written offer details (principal/advance amount and any rate/pricing/cost or total repayment/remittance amount) to a merchant and state that the offer is the only one presented by Credibly. Presentation of a single offer triggers the disclosures and a single offer has not been made by Credibly until you select one in the Offer Calculator. Until you have selected an offer and contracts have been generated and sent to the merchant, if you are providing offers in writing (including text message) you must communicate multiple Credibly offers to the merchant."

"Once you’ve selected an offer in the Offer Calculator for your California merchant, you will notice a new pop up window. You’ll have to click to confirm prior to sending/downloading the contract."

California licensure requirements are separate from the disclosure requirements. To my knowledge, the new disclosure requirements did not affect the licensure requirements that have long been in place.