We’re down to the last few weeks of the year and the final deadline for implementation of the SAFE Act. As we get closer to the December 31 deadline, you can begin to expect an increase in the number of calls from MLOs wanting to make sure their PE or CE course credit are posted in NMLS. You can help to reduce the number of calls by ensuring that you credit bank as soon as possible after the course has been completed. Here are a couple of other tips to keep in mind:
– Ensure MLOs provide you with their Unique NMLS ID number prior to starting the course.
– If a student completes a course and does not have an NMLS ID number, credit bank all other students as soon as possible and then go back and report the other student later when he/she has their number.
– Make sure you have the course offering set-up in PULSE prior to offering the course.
– Some students are confused about how to read the course completion record. Instructions and a link to a quick guide on how to read the record were posted below on November 15th.
Just a reminder that tomorrow is the last day to submit Late CE courses. Late CE courses are those courses that an MLO will be allowed to take to make-up CE requirements during a 60 day reinstatement period following the annual licensure renewal period. The new category of Late CE courses will be made available January 3, 2011.
If you already submitted a Late CE course, NMLS will be processing the course application fee refund later this week and checks will most likely be sent out the second week in December.
NMLS will be closed November 25 and 26 for the Thanksgiving holiday. Providers are reminded that no invitations to upload course materials in the course approval (Basecamp) as part of the course submission or renewal process will be sent until November 29th. PULSE Portal will be available for the extended holiday weekend for credit banking; however, the customer service desk will be closed.
NMLS has posted the updated Policy on the Use of NMLS Name in Course Marketing. The updated policy now includes a requirement for course providers to include the course name and course ID number as approved by NMLS in marketing materials and on web sites. The updated policy is intended address a frequent complaint from MLOs that course titles and numbers which are found in the NMLS Master Course Catalog do not always correspond to what an MLO sees in marketing material or on a provider’s web site. The change is also intended to assist MLOs to better distinguish between approved course provider courses and courses being offered by other non-approved organizations.
NMLS wished to express its thanks to those providers who provided comment on the proposed policy change during the public comment period which ran from November 8th to the 18th. The updated policy can be found in the course provider section of the NMLS Resource Center at: http://mortgage.nationwidelicensingsystem.org/courseprovider/Pages/Resources.aspx
NMLS has released the third quarter student survey report. The report is a summary of surveys that NMLS sent to students who completed courses between July and September, 2010. A primary objective of the surveys is to measure student’s perceptions of the quality and effectiveness of the courses they are required to complete in order to meet licensure requirements in accordance with the SAFE Act. The surveys focus on measuring instructor effectiveness, perceived course quality, instructor-to-student or student-to-material interaction, course rigor, and learning outcomes. The survey results are used as a measure to assist NMLS to understand how courses are being delivered and to prioritize initiatives and/or policy changes that may need to be undertaken as a way to improve course quality. Individual survey results are shared with course providers on a regular basis; NMLS produces an aggregate report on a quarterly basis.
The report can be access from the course provider page in the NMLS Resource Center at: http://mortgage.nationwidelicensingsystem.org/COURSEPROVIDER/Pages/default.aspx
NMLS has begun to experience a significant increase in calls about CE courses not appearing on an MLO’s course completion record. A review of the individual’s record usually reveals that the information has been recorded and the MLO just didn’t know how to review the information. When assisting MLOs please keep the following in mind:
– CE information is not displayed on the same report as PE. To review a CE record, the MLO must go to composite view in NMLS, then view education, and then from the drop box pick CE (instead of PE) and then type in the year (2010).
– If an MLO completed PE in 2010, NMLS has been programmed to not look for CE this year which means an individual’s record will not show “CE Compliant” under the “PE Compliant” message. This does not necessarily mean that the individual did not complete CE; it just means that under certain conditions the system is not programmed show “CE Compliant.” Drilling down to a specific record will show education has been completed.
– A QuickGuide and instructions on how to view a Course Completion Record can be found at: http://mortgage.nationwidelicensingsystem.org/licensees/resources/LicenseeResources/Course%20Completion%20Records.pdf
Although one of the purposes of RESPA Reform was to improve the disclosure of Yield Spread Premium “YSP”, it continues to be a confusing topic within the mortgage industry (and one of the biggest deficiencies during course renewal). RESPA does not prohibit the payment of YSP; RESPA does require disclosure of the YSP. It is important that courses on RESPA provide clear information regarding the payment of YSP.
When there is YSP to be paid on a loan, the dollar amount of the YSP is reflected in Block 2, page 2 of the Good Faith Estimate. The amount is reflected as a credit or reduction toward overall closing costs. This amount is paid or credited directly to the Borrower. (Federal Register Vol. 73, page 68226).
The amount the Broker can expect to be paid is reflected in Block 1, page 2 of the Good Faith Estimate. “Block 1 must include all charges to be paid by the borrower that are to be received by the broker and any other originator for, or as a result of, the mortgage loan origination, including any payments from the lender to the broker for the origination.” (Federal Register Vol. 73, page 68226). This Origination Fee is part of the overall closing costs being reduced by the credit made to the Borrower for the YSP.
One caveat to keep in mind, in 2011 the topic of YSP is going to be changing once again. Refer to Section 1403, Title XIV Mortgage Reform and Anti-Predatory Lending Act of Dodd-Frank Act (HR 4173). If you are discussing payment of YSP within RESPA, the student should be informed of upcoming changes.
Federal Register Vol. 73 http://edocket.access.gpo.gov/2008/pdf/E8-27070.pdf
RESPA Final Rule http://www.access.gpo.gov/nara/cfr/waisidx_09/24cfr3500_09.html
Dodd Frank Act (HR 4173) http://www.govtrack.us/congress/billtext.xpd?bill=h111-4173