Moving Your OCCC License from ALECS to NMLS: What Texas Dealers Are Asking

• By: Gabrielle Faust
• On: 09/14/2026 11:54:59
• In: Texas Posts
• Comments: 0

By Hugo C. Sanchez, CPA
     Butler & Sanchez LLC

We've walked a number of our Texas clients through this filing over the past several weeks, and the same short list questions keep popping up. Here’s the answer to some of those questions:
 
What's the deadline?
 
September 30, 2026. The OCCC granted a one-time extension from the original August 31 date, and this one is final. Applications filed by the 30th will keep being reviewed until approved, you just need to have it submitted by the 30th. Miss it and you'll be filing a brand-new license application through NMLS — additional requirements and significantly higher fees. If you haven’t started on this, do so asap.
 
NMLS wants an IRS document and I can't find my SS-4. Now what?
 
First, check with your CPA or bank; they may have a copy. Your CPA should be able to get a Letter 147C or transcript from the IRS a bit quicker if they have a Power of Attorney on file.
 
If they don’t have a copy, you will need to request a Letter 147C. You can call the IRS Business & Specialty Tax Line at 800-829-4933, Monday through Friday, 7 a.m. to 7 p.m. The IRS representative generates the letter during the call and can fax it to you right away; by mail, it will take a week or more. The IRS will only give you the letter if you are the owner, a corporate officer, a partner, or the responsible party on the EIN record.
 
You can also create an online IRS Business Tax Account as a Designated Official of your business. You will need to confirm your identity by using the ID.me system, they will then mail a PIN which you will need to wait for to gain full access to the account, again, getting the PIN could take a week or longer. Once you have the PIN and access to account, you can get an EIN verification letter or transcript online.
 
My Secretary of State name doesn't match my IRS records, how do I change it?
 
NMLS requires an exact match between your legal entity name and your IRS records. Any small punctuation or spelling difference will reject, including L.L.C. vs LLC or Inc. vs Incorporated. Unfortunately, the only way to fix this is by mailing the IRS a signed letter requesting the name change so their records match your Articles of Organization. The IRS is incredibly behind on processing any mailed documents, so this will take some time. If you have not yet filed your business tax return, you can ask your CPA to change the name on your return and mark the box for “Name Change” to help speed things along.
 
Hugo C. Sanchez, CPA
Butler & Sanchez LLC
hugo@butler-sanchez.com
832-742-1300