New Jersey Confirms Revised Delegate Reporting Requirement
New Jersey Confirms Revised Delegate Reporting Requirement
New Jersey Confirms Revised Delegate Reporting Requirement
The New Jersey Department of Banking and Insurance (DOBI) has revised their interpretation of the quarterly authorized delegate reporting requirement under N.J.S.A. 17:15C-12(c), applicable to all licensed money transmitters operating in the state. The guidance, recently confirmed directly with the Agency, clarifies that licensees with no authorized delegates must submit a quarterly email confirmation to DOBI. Notably, DOBI has not cited this requirement as a deficiency in recent examinations, but FS Vector anticipates this may become a new area of exam focus.
All licensees must file a quarterly report within 45 days after each quarter end, whether reporting delegate additions and terminations or confirming no authorized delegates were active during the period. Submission format is determined by total delegate count.
Key Requirements:
- Licensees with no authorized delegates must submit an email to DOBI confirming no changes occurred during the quarter
- Licensees with a limited number of authorized delegates must complete and submit the Authorized Delegate Form
- Licensees with more than 25 authorized delegates must submit the Authorized Delegate Spreadsheet
Quarterly reports are due within 45 days after each quarter end (May 15, August 14, November 14, and February 14) and submitted via email to bliconline@dobi.nj.gov.