DFPI Escrow Requirements: Updating Your Office Procedures
Translate current DFPI reporting requirements and commission-disbursement guidance into a clear office procedure.
An office procedure should point to a current requirement, not just a headline about a regulatory change. Separate the continuing Escrow Law obligations from a new bulletin, a changed invoice and the office's own control choices.
Start with the current DFPI requirements
DFPI's post-license requirements page lists an annual assessment of $7,215 per licensed location. Use the actual assessment notice to confirm the amount and payment deadline for your company. This guide does not establish the effective date of an increase or a phased billing schedule.
Keep separate calendar entries for the annual audit report and the Report of Escrow Liability. The former is generally due within 105 days after fiscal-year end; the latter is due February 15 for each licensed location. Assign a preparer, reviewer and evidence of submission for each.
These are distinct filings. A timely payment, a CPA engagement or a submitted liability report does not establish that the annual audit report was filed.
Review commission disbursement requests
The June 30, 2025 DFPI/DRE joint bulletin addresses Commission Disbursement Authorizations used to pay broker personal or business expenses and payments to unlicensed people or entities that may have performed licensed activity.
Do not convert that concern into a rule that every payment to an unlicensed payee is prohibited. Identify the payment's purpose, the parties' instructions, the relevant licensing question and whether trust funds may properly be used. Escalate uncertain commission splits or third-party payments before disbursement.
Update the procedure where the requirement is used
- Link the official requirement or bulletin in the office procedure.
- Identify the affected filing, payment or transaction step.
- Name the person who gathers evidence and the person who reviews it.
- State what causes a pause or escalation.
- Retain the completed record and the instruction version used.
For a filing, retain submission confirmation and regulator correspondence. For a disbursement, retain the instruction, supporting evidence, current payment details and the office decision.
Distinguish law from an office control
A pre-disbursement review, a second reviewer or an internal exception process can help the office organize its work. Do not describe those choices as newly enacted DFPI rules without a specific source.
An owner may approve a permitted departure from internal policy. That approval cannot override law, missing party authority or a regulator's order. Material changes should return to the responsible reviewer before action.
Prepare for examination
Keep the current reporting calendar, applicable bulletins, filed reports and evidence of corrective actions together. Use the examiner's request and the current rules to determine required record formats and access. Avoid assuming that a generic checklist predicts every examination finding.
Review the official Escrow Law page when updating procedures. This article is an operational starting point, not a complete inventory of legislative or regulatory changes in 2026.
Sources
One page in the file before money moves.
Your office decides. Veto records what was reviewed, what stayed open, and who reviewed it.