NMLS has received several requests to clarify item 1A of the Course Provider Standards-of-Conduct which states all advertising and marketing must be truthful and be void of any misleading statements, promises, or guarantees (e.g., a course may not be promoted in such a way as to guarantee that an individual will pass a test after completing the course). Specifically, questions have arisen pertaining to certain advertisements from NMLS Approved Course Providers that have recently appeared in which providers are offering to reimburse students their test fees if they fail either the national or state components of the MLO SAFE test after they have taken the provider’s course.
Providers are prohibited from guaranteeing that students will pass the MLO SAFE test as a result of taking their courses. Guarantees of this sort are unenforceable. Simply put: it would be nearly impossible for a provider to guarantee an individual will pass the test. However, providers may make “money-back guarantees.” In these cases, providers guarantee that they will refund students the cost of the course, or the test fee, or both if students do not pass the test and have prepared for the test by taking a provider’s course. Providers that wish to make these types of guarantees must adhere to their normal refund policies, must make the guarantee offers uniformly available to all students, and must communicate the guarantee and refund language in clear and simple language.
The final version of the Functional Specification for Online Self-Paced Courses has been posted in the course provider section of the NMLS Resource Center. NMLS would like to extend its thanks to those organizations that submitted comments on the draft version that was posted in mid-March. Many of the comments received have been incorporated into the final version of the document.
Course providers who are considering offering online courses need to be aware of the technical requirements outlined in the functional specification. Courses that do not conform to the technical specifications outlined in the document will not be approved. Additionally, provider should take note that the specifications associated with offering online self-paced courses (online CE) differ significantly from those associated with offering instructor-led online courses (online PE). http://mortgage.nationwidelicensingsystem.org/courseprovider/Pages/Resources.aspx
The functional specifications for all classroom formats (except classroom) are available at: http://mortgage.nationwidelicensingsystem.org/courseprovider/Pages/Resources.aspx
Providers are reminded that there is a requirement to issue course completion certificates at the end of each course offering. A copy of the organization’s course completion certificates is required as part of the application process to become an approved course provider and NMLS maintains these on file. The certificate is important as it provides evidence that the student has completed the course. In the event a student calls to report that their course completion record in NMLS is inaccurate, the first document the student is asked to provide is the certificate. At a minimum, the certificate is to include the name of the organization, the course name and NMLS-assigned course number, the end date of the course, and the student’s name.
Verizon has corrected the communications problem that resulted in loss of connectivity with the PULSE system. PULSE is back online and course providers should be able perform credit banking, schedule course offerings and submit courses for approval.
NMLS has been informed that the PULSE is currently unavailable due to a network communications problem in the vicinity of the Pearson data center in PA. As a result providers cannot submit for approval, schedule course offerings or perform credit banking. Verizon, which is responsible for the communications link, is currently working to restore connectivity. We will post a notice as soon as the PULSE portal is available.
A large number of courses that are submitted for approval are returned to the provider with content deficiencies that need to be addressed. One question often asked is what needs to be done to get the resubmission evaluated more quickly? In addition to addressing all of the deficiencies, highlighting or “red lining” where changes have been made to the course is probably the single most important thing a provider can do to assist in the approval process. Highlighting changes helps the course evaluator(s) to quickly identify those areas where content has been updated and it reduces the amount of time it takes to re-review the content. Additionally, including page numbers on PowerPoint presentations and other documents assist the evaluator(s) to more precisely point out where deficiencies are located; conversely, noting changes to the original page numbering when resubmitting material will also greatly help the evaluator(s).
Since January there has been a requirement to cite references and include case studies in courses. The intent of the requirement to include references is to assist MLOs to better prepare for the National and State Components of the MLO SAFE test by exposing them to the laws and statutes that are contained on the test content outlines. The requirement to include case studies, particularly as they apply to state law, is to reinforce learning by providing context for how the laws are applied in real world situations.
To ensure providers have a clearer understanding of what NMLS is looking for when it reviews courses, the following documents have been posted in the NMLS Resource Center:
– A model PowerPoint presentation that includes instructor notes and provides examples for how to properly cite state and federal laws.
– A model course syllabus that includes examples of course descriptions, learning objective, and module time allocations.
These documents can be downloaded by going to the Notices and Examples section of the course provider resource page at: http://mortgage.nationwidelicensingsystem.org/courseprovider/Pages/Resources.aspx