Prepare Your Credit Union to Meet theSAFE Act RequirementsWednesday, January 12, 2011WebinarTim DoyleVice PresidentState Regulatory Registry, LLC
NMLS Federal Registration Part of the Nationwide Mortgage Licensing System &Registry (NMLS) Modified at the direction of the Federal banking agenciesand the Farm Credit Administration to implement the SAFEAct’s Federal Registration requirements:– Federally-regulated/insured institutions (and subsidiaries) willhave an account on NMLS– Each MLO to be federally-registered will have an account onNMLS2
NMLS Federal Registry Forms Form MU1R –Completed by institutions that must registerMLOs under final rule Form MU4R –Completed and attested to by MLOs
NMLS Federal RegistrationProcessInstitutions: Entitlement– provide basic information about institution– Identify contact person– Account Administrators Registration– Log into NMLS and register institution with NMLS byfiling Form MU1R
NMLS Federal Registration - MLOsMortgage Loan Originators1. Entitlement– Company or MLO can create individual record– Batch upload of some data2. Complete and Submit MU4R Form– Company manages process but MLO must personally attest3. Submit fingerprints for a national criminal backgroundcheck– Returned to institution for review4. Institution confirms employment5
Form MU4RContains:– Identifying information– Current Residential address– 10-year financial services-related employmenthistory– Current employer– Disclosure questions 15 questions covering criminal, judicial, regulatory,arbitration issues
NMLS Criminal Background Check NMLS is the channeler of criminal background checkand has developed a national network of electronicfingerprint sites The NMLS Criminal Background Check manages theentire process from MLO authorization to fingerprintcapture to return of the Criminal History RecordsInformation to bank through NMLS* NMLS manages the entire fingerprint and criminalbackground check process - there is nothing a bankmust do outside of NMLS.
2011 Federal Registry Fees MLOs– 60 initial registration fee– 0 annual renewal fee– 39 criminal background check fee (covers cost of scheduling,fingerprint submission to NMLS, and background check)– 30 MLO Change of Employment fee Institutions– 100 initial filing– 100 annual renewal filing– 70 two-factor authentication annual subscription fee foreach Institution User The 2012 fees will be the same except that the MLO initial registrationfee will be 30 prior to July 1st and 60 after July 1st and the annualrenewal fee will be 30.
Federal Registration ProcessStep 1: Determine if your Institution is Required to be Registered withNMLS Is federally chartered or insured by the Office of the Comptroller ofthe Currency, Board of Governors of the Federal Reserve System,Federal Deposit Insurance Corporation, Office of Thrift Supervision,Farm Credit Administration, and National Credit Union Administration(“the agencies”) AND employs individuals required to be federallyregistered as mortgage loan originators, your institution must registerwith NMLS. Definition of covered institutions and mortgage loan originators are contained inthe Final Rules published by the Agencies on July 28, 2010. Review and collect the information on Form MU1R that your institution will haveto submit to be registered: Form MU1R
Federal Registration ProcessStep 2: Get Prepared Each institution will be required to register with NMLS by submitting Form MU1R. When creating an account in NMLS, you must identify two individuals as NMLS AccountAdministrators. These Account Administrators will have primary responsibility for yourinstitution’s account on NMLS and can set up additional sub-users for your institution’saccount.– Each institution must have at least two Account Administrators– Each Account Administrator can perform all functions on NMLS on behalf of theinstitution, including setting up additional institution users– Account Administrators are the only ones who can contact the NMLS Call Center onbehalf of the institution Begin to review fields required on Form MU1R that your institution will have to submit andidentify the individuals who will be your institutions Account Administrators.
NMLS Federal Registration ProcessStep 3: Determine who needs to be registered Determine which employees within your institution meet thedefinition of mortgage loan originator according to the final ruleand review the registration information required from eachindividual on Form MU4R Review Form MU4R Fields
NMLS Federal Registration ProcessStep 4: Choose a Workflow The registration process can be accomplished several differentways. Three sample workflows have been developed to helpinstitutions develop a process that suits their needs:– MLO Completes MU4R & Institution Pays Fees– Institution Completes MU4R and Pay Fees– MLO Completes MU4R and Pays Fees Review the following sample workflows and choose the one thatis best for your institution.
NMLS Federal Registration ProcessStep 5: Obtain two-factor authentication for allinstitution users All Account Administrators and other users associatedwith your institution’s NMLS Account must utilize asecond authentication factor beyond the User Nameand password provided by NMLS before they are ableto log in to their NMLS account. Obtain security credential from Verisign(www.idprotect.verisign.com)
NMLS Federal RegistrationStep 6: Gather the necessary data from your MLOs tocreate their accounts Your institution will create the accounts for employeesthat you plan to register as MLOs. NMLS’ automatedprocess will allow your institution to batch upload yourMLO information in bulk to create their accounts onthe system. This batch upload process requires basicidentifying and contact information on each MLO. Collect the necessary information on your MLOs andfill out the batch upload file.
NMLS Federal RegistrationData required from your MLOs for Batch upload: First Name Middle Name Last Name Suffix SSN Date of Birth Email Address Phone Number Employment Start Date*
NMLS Federal Registration ProcessTo be completed starting January 31, 2011: Step 7: Request an institution account on NMLS Step 8: Complete and Submit your Institution’s Form MU1R Step 9: Repeat Steps 1 through 5 for each subsidiary whichis required to register MLOs Step 10: Begin registering your MLOs
2011 NMLS User Conferencewww.nmlsconference.org