California secondhand-dealer workflow

California Coin Dealer Reporting: Current Rules and the 2027 Transition

Coin-focused businesses should separate excluded coin and bullion property from other secondhand property they acquire. AB 2633 changes dealer-category language beginning January 1, 2027, but it does not make every coin transaction reportable.

Educational resource—not legal advice. Confirm obligations with DOJ, your licensing authority, or qualified counsel.

Through December 31, 2026

Apply pre-2027 law and current official guidance. Do not apply the AB 2633 amendments early.

Beginning January 1, 2027

The separate coin-dealer definition and exclusion are removed. Evaluate actual business activity, property, transactions, and exemptions.

Property exclusions remain

Coins, monetized bullion, and qualifying commercial-grade ingots remain excluded property. That is not an entity-wide exemption for other acquisitions.

Practical steps

  1. Inventory transaction types and property categories.
  2. Separate excluded coin, bullion, and qualifying-ingot transactions from other acquisitions.
  3. Review whether other activity may constitute secondhand-dealer business.
  4. Confirm state and local licensing requirements.
  5. Review legacy paper, fax, form, or account workflows tied to the former coin-dealer category.
  6. Monitor DOJ guidance for onboarding or account changes.

Covered activity creates mandatory duties. Beginning January 1, 2027, if your business acts as a secondhand dealer under the amended law, it must hold the required California secondhand-dealer license and report covered transactions to CAPSS under § 21628, subject to applicable property and transaction exclusions and exemptions. See AB 2633, amended BPC § 21626(b)–(c). This does not make every coin, bullion, or jewelry transaction reportable.

Frequently asked questions

Will all coin dealers have to report to CAPSS in 2027?

Not based on the business label alone. Coverage depends on actual activity, property, transactions, and exemptions.

Are rare coins reportable solely because AB 2633 passed?

No. AB 2633 preserves the exclusion for coins.

What if a coin shop also buys watches, electronics, or jewelry?

A shop that also acquires covered secondhand watches, jewelry, electronics, or other merchandise must evaluate those items under BPC §§ 21626–21629. Beginning January 1, 2027, covered secondhand-dealer activity requires the applicable § 21641 license and CAPSS reports for covered transactions, subject to statutory property and transaction exclusions. Coin-dealer status does not exempt unrelated acquisitions; not all watches or jewelry automatically qualify.

Organize covered transaction records in one workflow

EZ-CAPSS helps organize customer, item, transaction, submission, and retention information. It does not decide legal coverage or guarantee compliance.