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Breaking_NewsIn a surprise move, the IDFPR Division of Banking has rescinded the Mortgage Loan Originator (MLO) education rule it proposed in late April, which called for an additional three hours of Illinois-specific pre- license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.

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.

NMLS Rolls Out Uniform State Test

The Nationwide Mortgage Licensing System and Registry (NMLS) has announced that the Uniform State Test (UST) will be available for enrollment beginning 4/1/2013.  As I mentioned in a previous blog post, the goal of the UST is to eliminate the need for Mortgage Loan Originators to take two tests to obtain a license under any state regulatory agency that adopts the UST program.  Although we’ve known for a year now that the NMLS was planning this initiative to streamline the licensing process (and save states the time and money involved in maintaining their own individual tests), the details have just recently become available.  Here are the critical ones you need to know:

WHICH STATE AGENCIES ARE PARTICIPATING IN THE UNIFORM STATE TEST PROGRAM?

As of this writing, the following state regulatory agencies have signed on to the UST program effective on the following dates.

State agencies allowing test enrollments beginning 4/1/2013:

Delaware New Hampshire
Georgia North Carolina
Idaho North Dakota
Indiana Department of Financial Institutions* Pennsylvania
Iowa Rhode Island
Kentucky South Dakota
Louisiana Utah Department of Financial Institutions*
Maryland Virginia
Massachusetts Washington
Michigan Wisconsin

*NOTE: Indiana Secretary of State and Utah Department of Real Estate have not elected to participate in the UST program at this time.  Licensees applying to these agencies will still be required to pass a State Component Test in order to become licensed.

Agencies allowing test enrollments beginning 7/1/2013:

Alaska
Kansas
Nebraska
Vermont

The NMLS will add agencies to this list as they sign on to the UST program.  An up-to-date list can be found by going to the NMLS Resource Center and following the links on the right-hand side of the page.

WHAT IF MY STATE AGENCY WAS NOT LISTED?

If you wish to become licensed by a state agency that has not adopted the UST, you must continue to take their State Specific Component Test. If you will be taking the National Compnent Test on or after 4/1/2013, your National Component Test will include the UST.  However, the required State Specific Component Test (for a state agency that has not adopted the UST) will need to be taken separately in order to become licensed by that state agency.

HOW DO I ENROLL FOR THE UNIFORM STATE TEST, AND WHAT IS THE FORMAT?

There is no way to enroll for the Uniform State Test until 4/1/2013.  Once that date has arrived, you will open a testing window by enrolling through the NMLS system as you would any other test.  To my surprise, the NMLS did elect to offer the UST as a stand-alone test for those who have already passed the National Test Component.  Enrollment for the stand-alone UST will only be available for the one-year period running 4/1/2013 – 3/31/2014.  After that time, any individual who has not passed some version of the UST (either the stand-alone or the National Test Component with UST) will have to enroll for (and pass) the National Test Component with UST if they want to obtain a license from any state regulatory agency that has adopted the UST.

The cost to take just the UST (which will consist of 25 questions, all of which are scored) will be $33.00.  The questions will NOT be state-specific, but rather will relate to topics that are fairly uniform across all states; many will be based off of the SAFE Act model state law created in 2008.  The full text of that law in PDF format can be found here.  If you’d like to look at the UST content outline from the NMLS, click this link.

WHAT IF I’VE ALREADY PASSED A STATE TEST IN ONE OF THE STATES LISTED?

You will continue to be able to do business as usual.  You will not need to take the UST, unless you wish to obtain a license from one of the state agencies that have adopted the UST program after the exam becomes available.

WHAT IF I’M CURRENTLY SCHEDULED TO TAKE A TEST OR HAVE AN OPEN ENROLLMENT WINDOW?

If you’re currently scheduled to take a test, or have an open enrollment window to schedule a test, you will need to take the test as-scheduled and before the end of your enrollment window or you will lose the funds you have paid to open that enrollment window.  Failure to show for a scheduled exam will also close the enrollment window.  There is no way to switch an enrollment window from a State Specific Component Test to the UST once that enrollment window has been opened and during the time it remains open.

WHAT IF I NEED TO TAKE THE NATIONAL TEST COMPONENT?

After 4/1/2013, all NEW enrollments for the National Test Component will include the UST.   The National Test Component with UST will consist of 125 questions, 115 of which will be scored. There will not be an option to take the National Test Component without the UST.  The price for all National Test Component enrollment windows opened on or after 4/1/2013 will increase to $110.

All enrollment windows for the National Test Component opened prior to 4/1/2013 will be for the existing National exam and will not include the UST.  The cost for this will remain at $92.

Until 4/1/2013, there will be no way to open an enrollment window for the National Test Component with UST.  After 4/1/2013, there will be no way to open an enrollment window for the National Test Component without the UST.  The existing National Test Component will be administered until the last enrollment window closes.

WHERE DO I FIND MORE INFORMATION?

All pertinent information relating to the UST can be found at the  NMLS Resource Center under the TESTING tab.  You can locate the UST Implementation Information page from there.

Real Estate Institute offers UST exam prep programs. Free practice tests are also available.

Happy originating!

NMLS Issues Late CE Deadline Reminder

The NMLS issued a reminder to course providers that late CE reporting must be completed by February 28, 2012.  This will allow MLOs to apply for reinstatement by the deadline, February 29, 2012.  According to the NMLS, this is the absolute final deadline to have 2011 CE completed and reported to the NMLS.

Real Estate Institute’s comprehensive late CE course is specifically intended to meet the education requirements needed for you to reinstate your license.  Please note: Some states require mortgage loan originators to complete state-specific hours in addition to the CE hours required under the SAFE Act.  Be certain to confirm your state’s requirements for late CE reinstatement.

If you did not complete your 2011 CE requirement by December 31, 2011, the following course is approved and available for enrollment.  Real Estate Institute’s online, self-paced continuing education course is designed to help you meet your SAFE CE requirement in a convenient and engaging format.

Late 2011 CE: 8-Hour SAFE Comprehensive Continuing Education (NMLS-Approved Course ID: 2720)

The SAFE Act requires 8 hours of continuing education annually.  If you are unsure of your 2011 requirement, click here to view a helpful document on the NMLS website.  Click here for more information from the NMLS about license reinstatement.

CE Update and Warning from the NMLS

The Nationwide Mortgage Licensing System & Registry (NMLS) sent an email yesterday reminding mortgage loan originators (MLOs) about the annual continuing education (CE) requirement.  The NMLS warns MLOs that based on an upcoming system upgrade, MLOs may experience delays renewing their license.  Bottom line: DO NOT wait until the last minute to complete your CE and renew your license!

The NMLS email stated, “Please be advised that on October 1, 2011, an enhancement is being released in NMLS which, at a state’s discretion, will provide state regulators the ability to prevent an MLO from submitting an application to renew their license if they have not completed CE. A majority of licensing agencies using NMLS will make use of this new system functionality. Since it may take as long as seven (7) days for a course provider to report a course completion into NMLS, MLOs are strongly encouraged not to wait until the last minute to try to complete CE or they may be prevented from submitting for renewal on time. MLOs are encouraged to complete their CE as early as possible.

Additional information about CE and a link to approved courses is available on the NMLS Resource Center.  If you have questions about completing CE, please contact the NMLS call center at (240) 386-4444.”

As a reminder, the SAFE Act states that:

  • individual MLOs who are state-licensed must complete eight (8) hours of NMLS approved CE annually.
  • the 8 hours of CE must include: federal law (3 hours), ethics (2 hours with fraud, consumer protection, and fair lending issues), non-traditional mortgage lending (2 hours) and an elective (1 hour).
  • a number of states also have a specific number of state-specific education requirements that must be met. See the 2011 State-Specific Education Requirements Chart for details.

Real Estate Institute offers NMLS-approved CE that tackles critical, need-to-know issues facing mortgage professionals in 2011.  Don’t delay, enroll today for our upcoming 8-hour course.  Convenient online webinars and live classes are available.

Tick-Tock! The Clock Starts Monday for Annual NMLS Licensure Renewal and Credit Report Authorization

On November 1st, the NMLS will enable two new functionalities in the system that every licensed Mortgage Loan Originator will need to access:

1)      2011 License Renewal

2)      Credit Report Request

The license renewal process will be streamlined for all MLOs who have kept their NMLS record up to date.  We recommend logging in to the NMLS system and verifying all of your personal data prior to submitting your renewal request.  Fees for all states, the list of state deadlines and a handbook for the renewal process can be found at the following link: http://mortgage.nationwidelicensingsystem.org/slr/common/renewals/Pages/default.aspx

While you are verifying your personal information, please ensure that you have met your education, criminal background and testing requirements as well.  If you need assistance in figuring out what education you need to remain compliant with the law and continue to originate, don’t hesitate to contact us. 

We know you are responsible.  Does your regulator?
The “financial responsibility requirement” for licensure as an MLO was contained in the SAFE Act, however it has not drawn much attention recently for the simple fact that the NMLS system was not capable of handling the credit report processing needed to fulfill that requirement.  As of November 1st, the functionality will be made available, and all licensed MLOs will need to request a credit report prior to the deadline imposed by the state(s) in which they are licensed.  Most states have a deadline of March 1, 2011, although some require the report to be requested through the NMLS by December 31, 2010.  For example, Illinois’ deadline is March 1, 2011.  However, if you are licensed in neighboring Indiana and your license is issued by the INDIANA SECRETARY OF STATE, you must request your credit report by December 31, 2010.  Strangely enough, licenses issued by the Indiana Department of Financial Institutions have until March 1, 2011, to comply with the credit requirement.

Don’t leave your fate up to the state!
Note that there are no automated systems inside the NMLS system that will handle evaluation of credit reports.  Decisions on what constitutes “acceptable credit” are left entirely up to the state regulators.  We believe that Illinois will be more understanding of derogatory information than many other states, as long as there is a reasonable explanation.  In any case, expect states to require letters of explanation for all derogatory credit appearing on an applicant’s report.  If you have any concerns about derogatory credit affecting your ability to originate loans, please contact the state regulators FOR EACH STATE in which you are licensed (or hope to become licensed) and discuss your situation with them.

We don’t want to see anyone put in a position where one state approves a credit report but another state does not and rejects the license.  That would make it theoretically possible for individuals to have all of their licenses revoked or placed in a “refuse to renew” status.  While we hope that there will be procedures in place to ensure that does not happen, there is no guarantee.  Don’t take chances with your career when a simple phone call will answer your questions.

More information about the credit requirement, including the $15 fee for requesting the TransUnion report, can be found at the following link: http://mortgage.nationwidelicensingsystem.org/profreq/credit/Pages/default.aspx