Reg Relief a Reality – Now What?

Blue_Sky_CloudsOn May 24, the President signed the Senate bill known as the Economic Growth, Regulatory Relief and Consumer Protection Act (S.2155). You may have read a previous article I wrote that summarized the key points in this piece of legislation. However it’s worthwhile to reexamine them here before using a proven scientific method to predict what will happen next in the world of mortgage regulation.

Keep in mind that, while there are some significant provisions in this bill that benefit both consumers and the mortgage industry, the regulatory structure and disclosure regimes you’re used to at the federal level have not been affected. The CFPB is still the CFPB (albeit with a radically different approach to its mission under Acting Director Mulvaney), TRID is still TRID and the answer to the ultimate question of life, the universe and everything is still 42.

So, without further ado, here are the five parts of this much larger bill that are likely to affect originators and mortgage compliance professionals.

  1. Transitional MLO licensing. Without a doubt, this is the most important change for anyone on the front lines of our business, and one that the Mortgage Bankers Association has been advocating since the SAFE Act went into effect. The provision gives MLOs who work for depositories a 120-day window to originate loans after transitioning to a nonbank while securing their state license, meaning they would not need to lose valuable work time and income fulfilling the licensing provisions before speaking to consumers. This same 120-day grace period will also apply to currently licensed originators who wish to obtain a license in another state. 
  2. A small bank exemption from expanded HMDA reporting. Banks that originate fewer than 500 HELOCs and closed-end mortgages in a year have been exempted from reporting the expanded HMDA data points that went into effect with originations after January 1, 2018. Despite what you may have heard, this does NOT exempt these institutions from Regulation C altogether, merely from reporting the new data points such as disaggregated demographic information. This provision does not make any changes for other institutions, including nonbanks. 
  3. Eliminating the need for an additional 3-day waiting period when the APR decreases. Before you jump for joy at this one, the legislative language applies directly only to High-Cost mortgage loans. Although given the current leadership at the Bureau, it is likely to clarify through regulation or official interpretation that the same provision applies to loans that are not High-Cost as well (the Bureau has taken that position informally since TRID was enacted).

  4. Allowing consumers to freeze their credit reports without cost. This provision is a direct result of the massive Equifax data breach that shook the country in 2017. While credit freezes (that stop anyone from accessing a consumer’s credit file) have been around since the passage of the Fair and Accurate Credit Transactions Act, there has been a cost associated with them. Removing this cost will likely lead to more consumers placing freezes on their reports (and more MLOs needing to ask clients to unfreeze them to proceed with an application). Under the law, the bureaus are also required to inform consumers that these no-cost freezes are available.

  5. Providing Qualified Mortgage protection to bank portfolio loans. Depository institutions with assets under $10 billion receive QM protection on loans that they retain in portfolio without needing to follow all the documentation requirements in Appendix Q of the Qualified Mortgage rule. Before you start reliving 2007 however, keep in mind that such loans will still require verification of applicant income and assets, comply with prepayment penalty restrictions in the QM rule and not carry any interest-only or negative amortization features.

Where do we go from here?

While Congress is likely done with financial regulatory issues (at least for this session), the CFPB is, of course, under no pre-midterm election pressure. In fact, they’re scheduled to reexamine the QM Rule in 2018 due to the mandatory five-year review period specified in the Dodd-Frank Act. We know through various speaking engagements by Acting Director Mulvaney that this process is likely to lead to significant changes to the rule, although the scope and extent of those changes are not yet known. One of the areas of the rule that seems ripe for change is the 43% Debt-to-Income requirement exemption given to loans eligible for sale to Fannie Mae and Freddie Mac. Remember, this exception is temporary and is currently scheduled to sunset in January 2021. Thus, if not extended or made permanent, Fannie and Freddie loans would begin to be subject to the 43% DTI cap for QMs at that time. This could have a big effect on the marketplace by moving otherwise qualified loans out of the conventional conforming space and into FHA (adding risk to taxpayers), so look for this to be one of the focal points in an amended QM rule.

While we’re on the topic of regulation, remember the United States has a dual regulatory system where both federal and state governments have a say in regulating many financial services entities. It’s very likely that, as the CFPB pulls back on certain regulations, some states will move to continue or tighten them. Thus, compliance managers and MLOs alike need to remain focused on statehouses across the country for potential changes affecting rules in states in which they are licensed. This is especially true if there are leadership changes at the state level as a result of the off-year election results in November.

See you next month!


Peter



Real Estate Institute offers top-rated Mortgage Loan Originator Continuing Education and Pre-License courses in all three formats: Classroom, Live Webinar and Online, Self-Study. These courses were designed BY loan originators FOR loan originators covering topics you need to know to navigate today’s ever-changing lending landscape.


3 Tips for a Successful (and On-Time) MLO License Renewal

Hand writing the text: Time to RenewIt’s difficult to believe that another year has come and gone, and the license renewal period for Mortgage Loan Originators is now in full-swing. While this time of year generally involves visions of turkeys, football and sugarplums dancing in heads, let’s not forget that our careers also need some tending to prior to the end of the year. Here are some tips to make sure that the Grinch doesn’t steal your ability to originate loans in 2018.

  1. DON’T WAIT UNTIL DECEMBER 31!
    While it’s true that the federal SAFE Act sets a December 31 deadline for an on-time renewal application, waiting until the last minute won’t give the licensing agency time to process and approve your application before January 1. Some states will not allow you to originate new business (even with a timely renewal request) until your application has been formally approved, meaning that you will not be able to take applications or review loan terms with new clients until this happens; doing so could land you in hot water with your regulator and face discipline for unlicensed activity. Other States (like Georgia) have earlier deadlines for submitting on-time renewal requests, so please make sure you know the requirements for each state in which you’re licensed. For those of you in Illinois, the IDFPR will only guarantee that your renewal request will be processed before January 1 if you submit it by December 1.

  2. COMPLETE YOUR EDUCATION EARLY

    Most states will not let you submit a license renewal request through NMLS unless you’ve completed your continuing education requirement. Seems simple enough, right? Just do the education on December 30th and renew on the 31st! Unfortunately, to quote a recent nationwide commercial sensation, “That’s not how this works.”

    Course providers have seven days from the day you complete your education to report your hours to NMLS. This means that the latest you can complete education (in most states) and still be guaranteed a timely renewal is December 23. Note that Real Estate Institute will report all course completions until 1:00 PM on Friday, December 29 to allow some extra time, but even WE don’t recommend waiting that long! The good news is, If you need to get your education done, we have options to meet your needs through the end of the year.

  3. REMEMBER TO CHECK YOUR NMLS RECORD AHEAD OF TIME

    When logging in to NMLS, the “individual dashboard” will tell you how many licenses you have that are eligible for renewal, and how many you are prevented from renewing (generally because of issues like outstanding education or a required fingerprint submission). You’ll need to address any “deficiencies” prior to being able to submit for renewal, and you can find out what those are by clicking on the number of licenses that cannot be renewed. (This will take you to the renewal page, where you’ll have to click “attest and pay” to see a list of licenses that are not eligible.)

    Don’t wait until the last minute to check your record; allow yourself time to address any issues that may come up. This is ESPECIALLY true for those of you licensed in many states, as it’s easier than you think to forget a state-specific education requirement.

If you follow these three tips, you should have an easy and pain-free license renewal, not to mention a more enjoyable holiday season. As always all of us at Real Estate Institute appreciate your time and business, and we wish you the best for a successful 2018.

Happy Holidays!

Peter

NMLS Reminders for a Successful CE Season

Red bow on finger

According to the NMLS, the number-one question they receive from Mortgage Loan Originators is, “Do I need to do CE?” If you’re not sure, you should log into NMLS to review your education requirements. Your Course Completion Record will indicate whether you still need to earn Continuing Education this year. The NMLS has prepared a quick guide to help you navigate your record.

The NMLS also reminds MLOs that:

  • You may not complete the same CE course as last year.
  • Pre-license education courses do not count toward CE. However, MLOs do not need to take continuing education in the same calendar year in which they took an NMLS-approved 20-hour pre-license course.
  • Nearly half of all state agencies have a state-specific CE requirement. See the
    NMLS 2016 State-Specific Education Requirements Chart for the number of hours and other requirements.

  • Several state agencies have early CE or renewal deadlines. Check the state-specific education requirements chart for details.

Real Estate Institute offers top-rated 2016 CE courses in all three formats: Classroom, Live Webinar and Online, Self-Study. Try our courses and find out what it’s like to take CE that’s relevant and interesting.


LOAN ORIGINATORS: IDFPR RESCINDS PROPOSED EDUCATION RULE, ADOPTS UST

Breaking_NewsIn a surprise move, the IDFPR Division of Banking has rescinded the Mortgage Loan Originator (MLO) education rule it proposed in late April, which called for an additional three hours of Illinois-specific pre- license education and an additional three hours of Illinois-specific continuing education annually. The Division of Banking also confirmed plans to move ahead with adopting the Uniform State Test (UST) for loan originator license applicants in Illinois, effective June 1, 2016. For those unfamiliar, the UST covers general state-level regulatory information applicable in most states and is included as a part of the National Component of the SAFE exam that all potential licensees must pass.

Illinois State Test Component Removed Effective 6/1/2016

WHAT DOES THIS MEAN FOR YOU?

  • If you are currently licensed as a mortgage loan originator in Illinois, this has no impact on you. You may continue to originate as you have been doing.
  • If you are not yet licensed in Illinois but have already passed BOTH the National Component AND the Illinois State components of the SAFE exam, your Illinois license application will not be affected by this change. Whether or not you have actually filed the application, you do not have any additional requirements and may apply for licensure at any time if you have not already done so.
  • If you are not yet licensed in Illinois AND you have passed the National exam with UST (meaning you enrolled for and passed the National SAFE exam AFTER April 1, 2013), you will be able to apply for an Illinois MLO license on or after 6/1/2016 (do not apply before this date). This situation also applies to anyone who enrolled in and passed the STAND-ALONE UST, which was available in 2013 and early 2014.
  • If you are not yet licensed in Illinois AND you have not passed the Illinois exam AND you enrolled for and passed the National SAFE exam WITHOUT UST (you enrolled for the National exam BEFORE April 1, 2013), you have two options:

    Option 1: Enroll in the Illinois State Component exam BEFORE June 1st, 2016 and pass that exam on your first take OR;

    Option 2: Enroll for and pass the current version of the National exam with UST. Yes, this will require you to re-take the full national component, as there is no longer a stand-alone UST option.

If you have any questions about which exam(s) you have taken and passed, you can find that information by logging into the NMLS (on the State side), clicking the “COMPOSITE VIEW” tab at the top right, then clicking “View Individual” at the top center and finally clicking “Testing Information” on the left navigation bar. You can also contact the NMLS Call Center at 855-665-7123 with questions about your status.

Refer to the IDFPR press release announcing this change.


Real Estate Institute has helped thousands of LOs pass the SAFE exams with Prep-to-Pass. Our recently updated test prep program includes the most recent NMLS content outline revisions. Try sample practice tests for free at our website.

Is the CFPB Finally Listening on TRID?

TRID maze
According to the folks over at National Mortgage Professional Magazine, the CFPB has quietly begun drafting a Notice of Proposed Rulemaking. For those unfamiliar with the process, this is the first step in issuing a new or revised administrative rule, and typically opens the door for public comments on the topic at hand before the rule is actually drafted/released.

In this case, the topic at hand is the TILA-RESPA Integrated Disclosure Rule – or TRID – which totally revamped the mortgage disclosure process beginning in October of 2015. Since the new rules took effect, lenders have been struggling to comply with what they believe the CFPB wants, which in some areas is still unclear as the CFPB has not issued formal written guidance on many topics.

While there are positives that have come out of TRID – namely the effectiveness of the simplified Loan Estimate form that replaced the GFE for most transactions – there also have been many speedbumps. For example, many technology providers lagged behind in releasing updates to origination, document preparation and other software, which led to lenders issuing non-compliant Loan Estimates and Closing Disclosures. In fact, recently Moody’s estimated that up to 90% of loans originated in the first few months of the rule’s effective date contained at least one TRID-related defect.

A large mortgage lender – W.J. Bradley – closed its doors in March after being unable to sell a large number of loans with TRID compliance issues. This event, along with consistent industry prodding for help in understanding CFPB expectations through formal written guidance may have led to Director Cordray’s decision to revisit the rules.

While the NMP article indicates a “possible TRID rewrite,” I wouldn’t expect a massive overhaul of the key components that we’re becoming accustomed to in the origination community – namely the Loan Estimate and Closing Disclosure. Instead, what I believe is likely to happen is a clarifying tweak to some of the more confusing areas of the regulation, such as the sections dealing with construction and other non-traditional lending products, and (fingers crossed) significantly more written industry guidance to help us understand what we need to do to comply with CFPB expectations. If this is the case, that should make the secondary market (especially in the nonconforming space) much more comfortable in purchasing loans, which should result in an easing of credit availability and – one would hope – a reduction in loan turn-times which skyrocketed industrywide after October 1, 2015. It also may lead to a long-term reduction in compliance costs, which would make many small and midsized players in our industry very, very happy.

More on this as it develops. Until then, happy originating!

Peter

Here Come the Changes! Fannie Mae Sets Release Weekend for Desktop Underwriter™ 10.0

Here Come the Changes! Fannie to release DU 10.0

Well, we finally know a *LITTLE* more about Fannie’s plan to release the brand-spanking-new version of Desktop Underwriter™ (DU™).

If you took Real Estate Institute’s live Mortgage continuing education class last year, you heard me talk about Fannie’s plans to revamp and update their underwriting engine to take into account “new and improved” (*your mileage may vary) credit report data that the mortgage industry has not previously utilized. The data to which I’m referring is called trended credit data, and it incorporates much more information about consumers than most of you have ever seen before.

Right now, our mortgage credit reports are basically “snapshot” reports – that is, they show the consumer’s payment history, current balance, credit limit, dates opened, etc. That data is updated typically once per month from each reporting account, and what we know about our customer is what is reported on that day from that creditor. Thus, if Joey Bagadonutz is someone who pays off his credit cards in full each month, but his outstanding balance on the day the account reports to the bureaus is $3,500, we see that balance as $3,500 with no indicator of how long it has been that high. Now, imagine that the limit on Joey’s account is $4,000. Our current underwriting algorithms see him as a SIGNIFICANT CREDIT RISK because of his credit utilization. Not good for Joey.

With trended data, not only will we be able to view the outstanding balance and limit, we’ll be able to see how much Joey has paid on his accounts each month for the past two years! For a guy like Joey who pays his account in full, this is fantastic; we’ll be able to really dig into his excellent credit history beyond today’s “well, he’s never been late.” Thus, Joey gets a better risk evaluation, which leads to a better rate, which leads to happy Joey, pink unicorns, rainbows and Santa Claus! Can’t get any better than this, right?

Well, if you’re Joey, yes.

However, if you’re someone who carries a balance each month, not so much. Let’s say you’re working with Bubba Buysalot on a purchase of a new home. Bubba is a guy who has 6 open credit cards, is under 50% utilization on all of them, and has never missed a payment. In today’s credit world, our algorithms see him as a TOP-TIER RISK LEVEL because of his utilization and payment history. Good for Bubba. Now, with the new trended data, we dig deeper and see that Bubba has made just the minimum payment on all six accounts and his balance over time has been increasing. Now, Bubba is no longer a top-tier borrower. He gets a worse risk evaluation (due to the fact that those who make minimum payments default on debt at a rate 3 to 5 times higher), which leads to a higher rate or a declined loan, which leads to sad Bubba, rain clouds, bee stings and Lucy pulling away the football when he tries to kick it.

You can see both sides of this coin, right? Deeper information and improved risk assessment is good for creditors, Fannie Mae and MBS investors, but it’s not good for every applicant.

OK. So WHEN is this new version of DU coming out? Good question. According to Fannie’s preview document released at the end of January, we can expect the rollout to occur on the weekend of June 25, 2016. We also can expect a series of training webinars and informational communications in the months leading up to the roll-out date. As of right now, all we really know is that this new release will evaluate trended credit data, as well as simplify the process for applicants with multiple financed properties. We’ll learn a lot more when Fannie issues the release notes sometime later this month. It will be interesting to see if they also incorporate some of the other changes they’ve been working on, such as creating a way for DU to evaluate borrowers with non-traditional credit histories, or if those will be relegated to a future release.

Now that you have this knowledge, it’s time to get out there and start educating your prospective borrowers about it, especially those who are sitting on the fence about purchasing a home. While you’re at it, start informing your referral sources, too! I’m sure there are gaggles of real estate agents and financial planners out there who’d like to know about these changes well in advance.

More to come when the Release Notes are, well, released. Until then…

Happy Originating!

Peter



Real Estate Institute is an NMLS-Approved Course Provider, #1400102. Each year, thousands across the country choose Real Estate Institute for its mortgage pre-license, SAFE test prep and continuing education programs. If you have questions about your education requirements, our compliance experts are available at 800-995-1700 from 8 a.m. – 6 p.m. (Central Time), Monday through Friday.

What Mortgage Companies Need to Know About Advertising to Stay Out of Trouble

Gavel_Regulation NSurely you’ve seen the recent headlines. The Consumer Financial Protection Bureau (CFPB) is cracking down on mortgage companies for unfair and deceptive advertising practices. These companies are incurring multi-million-dollar fines for improper advertising.  Understanding the rules is critical. Here’s an overview of what you need to know about REGULATION N: Mortgage Acts and Practices (Advertising) to stay out of the headlines.

Regulation N Defined

Regulation N is a CFPB regulation that is intended to ensure that mortgage credit is not advertised in a misleading manner and that there are no material misrepresentations made – either explicitly or implicitly – about any term or mortgage credit product in a commercial communication (advertisement).

Under Regulation N, it is unlawful to:

  • Misrepresent the amount of interest a consumer will be charged, including any misrepresentations of, or failure to disclose, negative amortization.
  • Misrepresent the APR, simple interest rate, periodic rate or any other rate. (This is also prohibited separately in Regulation Z.)
  • Fail to disclose whether separate payment of taxes or insurance is required or misrepresent the extent to which those payments are included in the consumer’s mortgage payment or loan amount.
  • Misrepresent the existence, amount or duration of a prepayment penalty.
  • Using the word “fixed” to describe an ARM, unless the term “Adjustable Rate Mortgage” is clearly used before the term fixed and it is obvious that the loan is an ARM.  (For example, you can’t advertise a “five-year fixed” unless that really is a loan that amortizes over five years with no rate change.  You can, however, advertise “an adjustable rate mortgage with an initial fixed rate period of five years after which time the interest rate may adjust once per year.”
  • Misrepresent the type of mortgage credit product.  For example, it is illegal to lead a customer to believe that a balloon loan is a fully-amortizing mortgage.
  • Misrepresent the amount of the loan, or the amount of cash or credit available to the consumer, including claiming that no payments are required in a reverse mortgage.  (The payment is made when the loan matures, and the borrower can also make payments at any time during the term.)
  • Advertise or imply that the mortgage company or loan product is sponsored by or affiliated with the government.
  • Insinuate that the advertisement in question is coming from the borrower’s current servicer when it is in fact not.
  • Tell consumers that they are pre-approved or guaranteed for a loan when that is not true.
  • Promise a refinance or loan modification unless that refinance or modification has actually been underwritten and approved and cannot change.

Finally, under Regulation N, all advertisements must be retained by the lender for a period of 24 months after their last publication or broadcast.

Helpful Hint for Prospective MLOs

If you’re thinking of becoming a loan officer, you will need to know Regulation N for the National SAFE mortgage loan originator exam. This is the licensing test that prospective loan officers need to pass to become a state-licensed mortgage loan originator. For more help preparing for the NMLS / SAFE test, try out these free practice tests.

 


Real Estate Institute encourages all readers to consult with a qualified attorney on all matters of law or regulation, as no blog post can or should be a substitute for competent legal counsel.

 

Why Loan Originators Will Regret Missing the NMLS Uniform State Test Deadline

5 to 12 clockIf you are like most mortgage loan originators, you’ve questioned the value of taking the Stand-Alone Uniform State Test (UST). You’re probably thinking, “I originate in only one state and have no plans to expand. Why bother?” Based on the consequences, you should seriously reconsider.

It does make sense that you’d have these thoughts.  Not long ago, over 80% of the state-licensed MLOs had only one license. It just didn’t seem worth it to take the time to prepare for the test and pay more fees.

However, just because you only originate in one state doesn’t mean you always will. Here are the questions that you need to ask yourself:

–       What if something happens and my plans change?

–       What if I take a new position with a company that originates in multiple states?

–       What if I move? (Most people who live in Chicago are asking this question after 44 days of snow this winter!)

–       What if I decide not to take the Uniform State Test?

There are harsh consequences if you don’t register for the Stand-Alone UST before the deadline. Starting April 1, 2014, if you want to become licensed in any state that has adopted the UST, you won’t have a choice. You will be required to take a new National Test Component. This time, the National test will have 125 questions. Based on the failure rates, it wasn’t easy the first time and it isn’t any easier now. The safer play is to take the Stand-Alone UST. It’s only 25 questions. With some test prep, you should ace it and have no regrets.

Time is running out. All you need to do is open a test window by March 31, 2014. You don’t have to take the test by this date. You have up to 180 days after you open the test window. Don’t miss this opportunity. The reality is that 39 state regulators have already adopted the UST, and more will follow suit. If there’s a chance that you might do business in another state, register for the test.

Once you pass, you can relax and let the chips fall where they may. If you move or want to expand your business, you’ll be one step closer to satisfying that state’s requirements.

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Real Estate Institute has helped thousands of licensees pass their exams. Click here to learn more about Stand-Alone UST test prep.  A new National Test Component prep program is also available. It has been updated based on the 2014 NMLS Content Outline and includes the 2014 rule changes. Try our free online practice tests.

Click here to register for the Stand-Alone UST with the NMLS. You must schedule your test with Prometric.

Top 5 Tips NMLS Wants Loan Originators to Know About CE Season

Today, NMLS sent approved course providers these tips for you to get through the season successfully:

  1. Review Your Course Completion Record.  The redesigned course completion record provides a complete history of every course completed by an MLO since 2009.  The record also tracks federal and state PE/CE compliance for every license that an MLO is approved for: a green checkmark next to a license type means the MLO is PE/CE compliant; a yellow caution symbol means education is required.   If an MLO does not have a requirement for CE in a given year, the record will say “No Federal CE Requirements” or “No State CE Requirements.”  (And if there is no requirement, the MLO does not need to take a course for that year for that license).   Directions for how to view the record are available at the NMLS Resource Center.
  2. Remember the Successive Year Rule: MLOs are prohibited by the SAFE Act from taking the same CE course in successive years (two years in a row).  If the same course is taken two years in a row, the course may appear on the course completion record with zero credit hours applied, and the MLO will have to complete another CE course.
  3. PE Does Not Count as CE: If an MLO has a CE requirement but completes a PE course instead, NMLS will not count the course as meeting the annual CE requirement and the MLO will be prevented from filing for renewal.
  4. Make Use of the State-Specific PE/CE Education Charts: The most current State Specific PE/CE Education Charts are dated October 1, 2013.  Each state agency has a chart which includes information on PE and CE requirements, any specific or unique information about the agency, and each agency’s annual CE deadline. This year’s documents also include information on the Uniform CE Policy and Q&A’s about the new course completion record.
  5. Credit Bank on Time: One of most frequently call/e-mail topics of the renewal period is from MLOs inquiring about missing course credit. Courses appear on the MLO’s record immediately following the successful completion of the credit-banking process (there is no delay).  Here are the main reasons why a course will not appear on the record:
  •  The provider is banking a large number of MLOs and an individual was missed.
  • The credit-banking process was initiated but not finished (usually because the fees were not paid and the roster expired).
  • The MLO did not have or did not provide a correct NMLS ID number.
  • The course provider did not report within seven calendar days of the course end date.

NMLS-approved CE is offered by Real Estate Institute. The successive year rule is not a concern. All of our courses are new for the 2013 CE season. Fast credit banking is a top priority. Our students are reported within seven days of their course completion (usually the next business day). Click here for information about CE courses.

As a reminder, NMLS initiated SMART deadlines. The CE deadlines for 2013 are as follow:

SMART Deadline: Friday, December 20
At-Risk-to-Miss Renewal Deadline: Friday, December 27
Guaranteed to Miss Renewal Deadline: Tuesday, December 31
*Note: Some agencies may have an earlier deadline.

NMLS Issues Continuing Education Reminder

On Friday, August 23, the Nationwide Mortgage Licensing System & Registry (NMLS-R) sent a reminder to all state-licensed mortgage loan originators (MLOs) who have not completed continuing education in 2013. Individual MLOs must complete eight hours of NMLS-approved CE annually. The SAFE Act requires three hours of federal law, two hours of ethics, two hours of non-traditional mortgage lending and one hour of elective credit.  Some states also have state-specific education requirements that must be met. See the NMLS 2013 State-Specific Education Requirements Chart for details.

NMLS also reminds MLOs that:

  • You may not complete the same CE course as last year.
  • Pre-license education courses do not count toward CE.  However, MLOs do not need to take continuing education in the same calendar year in which they took an NMLS-approved 20-hour pre-license course.
  • Most state regulators will prevent you from submitting an application for license renewal if you have not completed CE.

In 2014, new rules will go into effect and will impact every MLO.   Real Estate Institute’s all-new 2013 CE courses will prepare MLOs to understand these changes and remain compliant.