California 43M-41 vs. NPMA-33: When Do You Need Both?
If you do WDO inspections in California, you've dealt with this: the state requires its own form, the lender wants the federal form, and you end up filling out both for one inspection. Here's exactly when you need each, and how to avoid getting tripped up by the overlap.
The short answer
In California, the 43M-41 is always required. The NPMA-33 is sometimes required on top of it — typically when the lender demands it for VA or FHA transactions.
Per the SPCB's own FAQ: a Branch 3 company cannot provide the NPMA-33 in California without also completing the 43M-41. The state form is the primary document. The NPMA-33, when needed, is attached as a supplement.
California state law does not recognize the NPMA-33 in lieu of the 43M-41. Completing only the NPMA-33 for a California inspection violates state law, even if that's all the lender asked for.
What each form covers
The 43M-41 — officially titled "Wood Destroying Pests and Organisms Inspection Report" — is a broader form than the NPMA-33. It covers wood-destroying insects AND organisms (including wood-decay fungi), and uses California's unique Section 1/Section 2 classification system. The current revision is 43M-41 (Rev. 04/2015).
The NPMA-33 — "Wood Destroying Insect Inspection Report" — covers insects only (termites, carpenter ants, carpenter bees, reinfesting wood-boring beetles). No fungi. No Section 1/Section 2 classification. If you need to report fungi on the federal side, you use the separate WDO Attachment.
One of the most frustrating details about the 43M-41: it can't be saved with your filled-in information. The SPCB's own forms page explicitly states this. You can fill in the PDF on-screen, but when you save it, your data disappears. This single limitation is why virtually every California WDO inspector uses third-party software (PestPro, Bugbase, or similar) instead of the state's own form.
Section 1 vs. Section 2: California's unique system
No other state in the country uses this classification. Established around 1989–1990 through California legislation, it requires every finding on a WDO report to be categorized into one of two sections — and it directly affects who pays for what in a real estate transaction.
Section 1
Covers active infestations, active infections, and damage resulting from those conditions. Specifically: live termites, active drywood termite infestations, active fungus or dry rot infections, and the wood damage those conditions have caused. In real estate practice, Section 1 items conventionally fall to the seller to address. FHA and VA lenders typically require Section 1 clearance before the loan can close.
Section 2
Covers conditions likely to lead to infestation or infection, but where no visible evidence of active infestation exists. California regulations (CCR Title 16, §1990) list seven specific conditions: faulty grade level, inaccessible subareas with less than 12 inches clearance, earth-wood contacts, excessive cellulose debris, excessive moisture conditions, evidence of roof leaks, and insufficient ventilation. Section 2 items conventionally fall to the buyer.
There's also what the industry calls "Section 3" — but this isn't an official statutory designation. It refers to areas the inspector couldn't access and that require further inspection. Inspectors routinely list these separately, but the terminology is industry convention, not law.
Putting an active infestation finding in Section 2 instead of Section 1 — or vice versa — can inflate repair costs, create disputes between buyer and seller, and trigger complaints with the SPCB. When in doubt, remember: if there's visible active infestation, active infection, or resulting damage, it's Section 1.
Who can file these reports?
Only a licensed Branch 3 field representative or operator employed by a registered Branch 3 company can conduct WDO inspections and sign reports in California. This is codified in Business and Professions Code §8516(b). Having a Branch 2 (general pest) license doesn't qualify you for WDO work.
California's three structural pest control branches are: Branch 1 (Fumigation), Branch 2 (General Pest Control), and Branch 3 (Termite/WDO). You can hold multiple branches, but you must have Branch 3 specifically to do WDO inspections.
SPCB filing requirements
Every WDO inspection report must be filed with the Structural Pest Control Board within 10 business days of the inspection (per B&P Code §8516(b)). The filing fee is $4 per property address under the current regulations (CCR §1997), though the SPCB has proposed increasing this to $5 — the maximum allowed under B&P Code §8674. Companies must maintain pre-funded deposit accounts with the SPCB to cover these fees.
Failure to file carries real consequences: fines up to $2,500 per violation and potential license discipline. All filed reports become searchable public records for two years through the SPCB's WDO search system.
The SPCB Connect transition
In late 2025, the SPCB migrated from its legacy filing system (at wdopestboard.ca.gov) to a new "Connect" portal. The legacy system went permanently offline on October 17, 2025, with the new system scheduled to launch October 22, 2025. The transition didn't go smoothly — there were delays, "blackout dates" that didn't count toward the 10-day filing requirement, and virtual townhalls to help companies navigate the new system. The new Connect system now accepts credit card payments (previously companies had to mail checks or visit Sacramento). As of 2026, WDO filing is done through connect.pestboard.ca.gov.
Complaints and statute of limitations
Standard complaints against a licensee or registered company must be filed within 2 years of the alleged improper activity. Complaints involving fraud, gross negligence, or misrepresentation get a longer window: 4 years. This is governed by B&P Code §8621.
When you need both forms: a real-world scenario
Here's a typical situation: you're doing a WDO inspection on a property in San Jose for a VA purchase transaction. You complete the 43M-41 with Section 1 and Section 2 findings, file it with the SPCB within 10 business days. The VA lender also requires an NPMA-33. You complete the NPMA-33 — which only covers the insect findings (not the fungi you noted on the 43M-41) — and attach it to the report package. Both forms document the same inspection, but they use different structures and cover different scopes.
That's two forms, same data, entered separately. For one inspection.
Last updated April 2026. This guide is for informational purposes and does not constitute legal advice. Verify current requirements with the California Structural Pest Control Board at pestboard.ca.gov. Primary sources: California B&P Code §8516, §8560, §8621, §8674; CCR Title 16, §1990, §1997; SPCB FAQ on NPMA-33 (pestboard.ca.gov/forms/faq_npma33.pdf); SPCB Forms page (pestboard.ca.gov/forms/index.shtml).