Safe Act – NMLS Renewal FYIs
Safe Act – NMLS Renewal FYIs
It’s that time of year to complete the annual renewal for the Nationwide Multistate Licensing System (NMLS). The renewal period lasts from November 1st through December 31st.
Unless an MLO (mortgage loan originator) completed their initial registration after July 1st, they are required to update and confirm that their information on the NMLS Registry is correct. As a reminder, an institution must update and attest that the required institution information is correct in addition to confirming the registration provided by MLO employees.
If MLO registration is not renewed during this period, they will become inactive, therefore becoming unable to act as an MLO until requirements are met. Renewal requirements can be found within the S.A.F.E. Mortgage Licensing Act (Regulation G) 12 CFR 1007.103.
What are some other things to keep in mind as we close the calendar year?
- Have you trained your MLOs on their requirements?
- Added in 2014, with a revision to Regulation Z, training must be sufficient in frequency, timing, duration, and content to ensure the MLO has knowledge of state and federal regulations.This is also a good place to remind MLOs of their requirements to update the system registry within 30 days of a triggering event.
- Do you have tracking system for monitoring compliance with registration and renewal requirements?
- Have you done any testing (if necessary) to ensure all communication materials (e-mail signatures, stationary, loan origination systems, etc.) remain accurate with MLO identification numbers?
- Are your website(s) updated for your originators unique identifiers, too (an industry best practice)?
For additional information contact the author Karlee S. Page at kpage@fosaudit.com.
Karlee S. Page | Nationwide Multistate Licensing System | Safe Act - NMLS Renewal FYIs