To the best of my knowledge, it's not. Instead they've hired Thomas P. Brown at Paul Hastings LLP/UC Berkeley as well as the former DFI Commissioner, Bill Haraf, to lobby on their behalf for forgiveness while they perpetually violate the California Money Transmission Act. Both have done quite well. Brown met with Robert Venchiarutti at DBO on October 25, 2013 at the very least, and also filed documents with the CA Office of Administrative Law, which he revoked when the DBO promised to be nice to him over the phone.

https://archive.org/stream/california-dbo-emails-ii/Producti...

For his part, Venchiarutti got his current job with the then-DFI 12 days after settling a legal malpractice claim in Los Angeles, which he lied about under oath in 2010. In the same deposition where he lied about having been sued, he also admitted to having no qualifications at all for his work.

https://archive.org/details/robert-venchiarutti-letter

This is the guy responsible for letting money disappear at Mt. Gox (via Dwolla, with a San Francisco office) and most recently Xoom, where $31 million vanished overnight. But don't worry, his assistant Julio Prada literally has a blood pressure cuff in his office for when he gets too stressed and angry. (We know this because a former DFI employee sued them both.)

Just can't make this stuff up.