TopMortgage Compliance Update (1)

December 27, 2011


NMLS: Missing the Registration Renewal Deadline -
Toolbox for Registration Renewals

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On December 8, 2011, we discussed aspects of state license renewals and offered a Renewal Toolbox for Licensees. In this newsletter, we discuss the issue of missing the deadline for federal registration and we offer a Renewal Toolbox for Registration.

The S.A.F.E. Act provides that the renewal period for federal registrants expires on December 31st of each year.

But what if the December 31st deadline is missed?

There is some flexibility in the S.A.F.E. Act for missing the December 31st deadline.

In This Newsletter-1Back
Renewal PeriodRenewal
The renewal period is November 1st through December 31st of each year. If a financial institution and its MLOs do not renew by December 31st, they would be prohibited from originating residential loans.

Under the S.A.F.E. Act, all affected financial institutions and their MLOs must renew through the NMLS in the annual renewal period each year, but there is an exception for MLOs registering for the first time less than six months prior to the end of the annual renewal period.
  Initial Registration ExceptionInitial
Although all financial institutions must be renewed during each annual renewal period, the same does not always apply to the institution's MLOs.

If the MLO completes the initial federal registration less than 6 months prior to the end of the annual renewal period for that year, the S.A.F.E. Act permits an exception to annual renewal for that particular year.

For instance, an MLO who registered on or after July 1st of 2011 would not be required to renew in 2011.
Missing the DeadlineDeadline 
If for some reason the MLO misses the December 31st deadline for annual renewal, it doesn't mean the MLO may not again originate residential mortgage loans.

The result of not renewing is a change in status; that is, the MLO's unique identifier is placed into inactive status.

During the period of inactivity, the MLO cannot originate loans, but as soon as the MLO renews, the unique identifier  is placed into active status and the MLO may begin originating again.
To summarize: MLO unique identifiers that become initially active before July 1st must be renewed by the end of that same calendar year, as well as all subsequent years. MLO unique identifiers that initially were activated after July 1st are not required to be renewed by the end of that same calendar year, but must be renewed in subsequent years.

All financial institutions must be renewed on an annual basis, regardless of when the institution's unique identifier was activated.
 Further InformationInformation
For further information:

1) Download: Registration Renewal Toolbox.

2) Visit: NMLSR Streamlined Annual Renewals - Federal.
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Registration Renewal Toolbox
        • Preparation
        • Upload Requirements
        • Updating Records
        • Renewal Requests
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This communication is sent to our valued clients and colleagues, who regularly receive our Mortgage Compliance Updates, Compliance Alerts, Commentaries, and related publications.

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