The most-recent NMLS Ombudsman virtual meeting focused on the NMLS modernization effort, the State Examination System (SES), the pandemic and remote work, and the CSBS Money Transmitter Model Law.
NMLS Ombudsman Jim Payne noted that over the course of seven months, the Ombudsman’s inbox received an average of 18 emails per month, with the following constituting the top five categories of questions:
- Entitlement issues
- Testing questions related to the SAFE MLO test
- Filing consumer complaints
- The license application process
- The Biometric Signature (BioSig) ID program
Ombudsman Payne also noted the importance of improving the consistency of examinations from agency to agency, highlighting that policy work and system enhancements that encourage uniformity are key to reaching this goal.
The NMLS modernization effort and the SES
CSBS representatives Bill Young and Kyle Thomas provided updates on the NMLS modernization effort and the SES. With respect to NMLS modernization, the next big step will entail incorporating mortgage business-specific requirements, given that the mortgage industry makes up 75% of NMLS-managed licenses. Though Young confirmed that development of the new system is underway, he was unable to provide a specific timeline for release. Regarding the SES, Thomas noted that, since the system went live in March of 2019, there has been a higher level of activity than anticipated. He highlighted that well over 100,000 documents, responses to information requests, and other regulator-licensee exchanges have been handled through the system to date, which includes over 3,000 active company users.
The pandemic and remote work
MBA representative Kobie Pruitt addressed the current state of the pandemic, acknowledging that concerns remain high and, on behalf of the MBA, urged regulators to extend remote work guidance through the end of 2022. Along those same lines, panelists Bob Niemi from Bradley and Michael Stidham from Rocket Mortgage encouraged state regulators to reimagine branch licensing and remote work.
CSBS money transmitter model law
The meeting also addressed the definitions of “control” and “key individual” as defined by the CSBS Money Transmitter Model Law, with the meaning of “control” discussed at length. Importantly, the act’s definition of control is more expansive than what is now required for non-MSB licensees, raising concern for who would be impacted by such an expansion.
A recording of the meeting is available on the NMLS Ombudsman page. Comments and questions can be submitted to the NMLS Ombudsman via email to [email protected]. The next meeting will take place in 2022.