Just a reminder that the state of Illinois has amended the Residential Mortgage License Act to impose a registration requirement on all state-licensed Mortgage Loan Originators who also engage in loan modifications. If you are engaged in any loan modification activities on properties located within Illinois, you must register with the state by completing a one-question questionnaire on the IDFPR’s website. The URL for the questionnaire is http://www.obre.state.il.us/MLOSurvey/.
If you perform loan modification activities, you MUST register online by the deadline of December 22, 2012. There are no additional fees or requirements above and beyond registration.
**Also, Illinois now considers loan modifications a licensable activity. In order to perform loan modifications on properties located in the state of Illinois, you must hold a valid Mortgage Loan Originator license or be otherwise exempt from licensure. **
The Residential Mortgage License Act defines loan modification as “for compensation or gain, either directly or indirectly offering or negotiating on behalf of a borrower or homeowner to adjust the terms of a residential mortgage loan in a manner not provided for in the original or previously modified mortgage loan.” (Amended via HB 4521, effective August 3, 2012)
As of today, nearly 1,600 ILLINOIS ORIGINATORS who certified their pre-license education (PE) requirement have failed to pay the $15.00 NMLS invoice and ARE NOT COMPLIANT WITH THEIR PE REQUIREMENT. If you certified your pre-license education, exempting you from the 20-hour course, you MUST pay the NMLS $15.00 in order to have the certification added to your record. This fee is in addition to the fee you paid to have your name included in the certification upload.
So Close, Yet So Far
All individuals who certified their education and who have not paid their invoice by the end of the year will NOT be compliant with the education requirements and will be forced to take the 20 hour class in order to renew/reactivate their license. You can check your invoice status by logging into the NMLS system and clicking the “Invoice” link at the top of your home page. Unpaid certification invoices will be deleted from the NMLS system on January 1, 2011 and there will be no way to pay them after that date, so the full 20 hours of pre-license education will be required.
Don’t Close the Door on Your Career Opportunities
If you are not planning on renewing your license, but certified your pre-license education requirement, it only makes sense to pay the $15.00 fee. Once this is paid, you will be compliant with the PE requirement and that certification will remain on your record for 5 years. If you do not pay the $15.00 invoice, and decide you would like to re-enter the business, you will have to pay over $300 for a 20 hour pre-license course.
Additionally, you should know that, if you exit the business in 2010 and re-enter the business in a subsequent year, you will still be responsible for completing your continuing education requirement for 2010! That will have to be done through a special course which will likely cost more than the regular course. If you are even thinking of getting back in the mortgage business in the future, save yourself time and hassle and take your CE before the end of the year.
Remember, if you take a 20-hour PE course in 2010, you do not need to take continuing education in 2010. However, if you have fully completed the pre-license certification process by paying your NMLS invoice, you do need to complete an 8-hour continuing education course in 2010.