NEWS: This is a reminder that the Nationwide Multistate Licensing System (NMLS) annual renewal period opened on November 1st and will remain open until December 31st. This requirement is from the federal Secure and Fair Enforcement for Mortgage Licensing Act (the SAFE Act) and the Consumer Financial Protection Bureau’s (CFPB’s) Reg. G that requires both covered financial institutions and individual mortgage loan originators (MLOs) to renew their registrations annually.
Credit union MLOs are required to register on the NMLS, as we explain in ii Release No. B070 – Registration of Mortgage Loan Originators. Different, more extensive licensing and registration requirements apply to MLOs employed by CUSOs or other businesses that are not federally regulated financial institutions.
Regulation G defines a covered financial institution as a bank or credit union that employs at least one MLO. An MLO, by definition, is an individual that:
- Takes residential mortgage loan applications; and
- Offers or negotiates the terms of residential mortgage loans for compensation or gain.
During the renewal process, the credit union’s SAFE Act administrator should confirm that the following information about the institution (credit union) is correct in the registry:
- Credit union name,
- Main office address,
- Contact information,
- IRS Employer Identification Number (EIN) number,
- Research Statistics Supervision and Discount (RSSD) number,
- Identification of its primary federal regulator,
- Name and contact information of its primary point of contact for the registry, and
- Name and contact information of its SAFE Act administrator.
During the renewal process, each mortgage loan originator at the credit union should confirm the following information is correct in the registry:
- Identifying information (e.g., name, home address, Social Security number, date of birth, etc.),
- 10 years-worth of financial services-related employment history,
- Any convictions of certain criminal offenses,
- Any civil judicial actions against the loan originator brought in connection with their financial services-related employment,
- Actions and/or final orders brought against the loan originator by a state or federal regulator,
- Customer-initiated financial services-related arbitration brought against the loan originator, and
- Fingerprints.
A Loan Originator Renewal Guide is available from the NMLS here.
In addition to renewing a registration every year, a registered MLO must update their registration within 30 days after:
- The registrant changes his/her name;
- The registrant ceases to be a credit union employee; or
- The “required employee information” becomes inaccurate, incomplete or out of date.