Monthly Archives: October 2016

NMLS Point of Contact

Just a reminder to the course provider community the following points of contact:

Questions regarding the EMS, credit banking, course offerings, or corrections need to be directed to Britton Anderson (

Questions regarding course approval status should be directed to Jessica Esquina (

Questions regarding course exams or compliance should be directed to Michelle VanderNaalt (


Updated Education Notices Posted for Colorado

NMLS approved course providers are advised that updated State-Specific Education Notices has been posted for Colorado.  Effective January 1, 2016, CO established education requirements for both PE and CE with the intent for DORA to update their CE content requirements every year.  To make it easier for course providers, NMLS has split the CO notice into separate PE and CE.  The new CO CE content requirement is effective January 1, 2017.

The CO notice and all other Education Notices are available on the policy page of the course provider section of the NMLS Resource Center.

2017 Functional Specification for Courses Posted

On an annual basis SRR reviews the Functional Specification for NMLS Approved Courses to ensure the specification and other requirements are achieving intended outcomes.  When the Course Provider Working Group (CPWG) was established in 2015, it assumed a role to make recommendations for updates or changes to NMLS.  Changes to the document are then required to be approved by the Mortgage Testing and Education Board (MTEB) and the NMLS Policy Committee.

For the 2017 document, the CPWG submitted to SRR two recommended changes to the document (details below).  These recommendations were approved by both the MTEB and the NMLS Policy Committee during their recent respective monthly meetings.  The updated Functional Specification has been posted the NMLS Resource Center and is effective January 1, 2017.

Summary of Changes:

Change 1: Remove the word “cohort” from the requirements for seat time and interaction in Online Instructor-led Courses.

Background:  In an effort to promote greater student-to-instructor interaction, SRR updated the Functional Specification in January 2015 to require a course that is five or fewer hours to not extend for more than 12 hours (prior the change, a course of only a few hours could be delivered over a period one or more days).  The change achieved the intended outcome and SRR has seen a significant increase in interactivity.   There is also a requirement, however, that online PE courses also be delivered with students progressing through the course as a cohort under the tutelage of an instructor (as opposed to self-paced).

As part of a cohort students are expected to begin work, complete assignments, and end the course at approximately the same time.  Generally this is a simple concept when a course is many hours or days long.  The timing becomes complex, however, as the number of hours decrease.  Given the large number of short state-specific courses being delivered and the competitive nature of the industry, uniform accountability for how a cohort begins, progresses, and ends has become as a significant challenge with some providers seeking advantage and/or feeling penalized because they are following the “rules.”

Recommended: Change to Section 1.5.6 removing the word “cohort” which requires students to progress through an online course a part of a group with the same start time.

Sect. 1.5.6 Current Language

NOTE: Online instructor-led (online PE) courses are required to be designed and delivered such that the instructor leads the course with all students as part of a cohort through instructor-to-student/student-to-student interaction.  This interactivity is required to be continual and obvious throughout the entire course.

Sect. 1.5.6 Revised Language

NOTE: Online instructor-led (online PE) courses are required to be designed and delivered such that the instructor leads the course with all students through instructor-to-student/student-to-student interaction.  This interactivity is required to be continual and obvious throughout the entire course.

Change 2: Allow for a limited number of untimed activities outside of the Learning Management System.

Background: Over the years, SRR has frequently received complaints from the industry that online courses take longer to complete than the number of hours they are approved for.  Under the leadership of the CPGW, a team was formed with the charge to “collect data, share information, and provide recommendations to SRR for ways to improve the Functional Specifications as it relates to the timing requirements for online self-study courses.”

Over the course of a three month period the CPWG collected internal data from their own course delivery systems.  Members anticipated their own data would support a conclusion that online self-study courses typically take longer to complete than the hours they are approved for.  This proved not to be case.  However, the CPWG continued to discuss ways in which the educational experience could be enhanced while maintaining time integrity.

Recommended: Allow students to complete a limited number of activities outside the Learning Management System (LMS).

Sect 5.2.7 (New Language)
Approved Untimed Activities:  Certain untimed activities may be utilized in modules.  A maximum of two untimed activities may be included for each hour of approved credit, with a maximum of five minutes per activity counting towards the amount of credit granted.  Examples include but are not limited to on-line field trips, case studies, and learning games.  Providers must include methods to ensure the rigor of the activity and student comprehension through quizzes or other appropriate methods of assessing understanding.

Are You Ready for CE Season?

The annual CE season is getting underway and we’re beginning to experiencing an increase in calls asking about education. Here are a few reminders and resources to help answer questions:

  • Checking if CE is Required: The number one question we receive is “Do I need to do CE?” MLOs should be encouraged to log into NLMS to review their education requirements by looking at their Course Completion Record. The course completion record displays icons informing MLOs if a course is required. The green check mark means they are CE compliant; a yellow “yield” symbol means a course is required. Here is a Quick Guide on how to view the record.
  • Successive Year Rule: In accordance with the SAFE Act, MLO’s may not take the same course two years in a row. MLOs are encouraged to view their Course Completion Record to see which course(s) they completed last year.  Note that there is absolutely nothing we can do to help an MLO or a course provider if an MLO completes the same course as last year except to advise them to take a different course.  If you attempt to credit bank and receive the error message “violates successive year rule” then it means the course has already been reported or the MLO completed the same course last year.
  • Credit Banking within 7 Days: Course providers are required to report course completions within 7 calendar days of the course end date. To avoid phone calls, course providers are strongly encouraged to report completions as soon as possible.
  • Incorrect Credit Banking: We have already seen an increase of courses being reported to the wrong MLO.  Course providers are strongly encouraged to work with students to get their NMLS ID number prior to or during the course and not after.  The use of NMLS Consumer Access as a means to acquire an NMLS number is not a good practice.  If a course is incorrectly reported please report it to Britton Anderson (  Note that in some cases, as part of correcting a record and where a compliance status may be impacted, state regulators may be notified.
  • State-Specific Education: Nearly half of all state agencies now have a state-specific CE requirement. The number of hours and/or any other unique requirements are detailed in the State-Specific Education Charts. Remember, courses that are intended to satisfy a state requirement have the two-letter state abbreviation in the course title.
  • Unique State Requirements: CA-DBO, NY and UT each have unique requirements that MLOs need to pay attention to. See the State-Charts for details.
  • Early Deadlines: Several state agencies have early education or renewal deadlines. See the State-Specific Education Charts for details.

Points of Contact:

Questions from students/MLOs about education requirements, license renewals, or any license status questions need to be directed to the NMLS Call Center: 855-665-7123.

Questions from Course Providers regarding credit banking, troubleshooting, or any other questions should be directed to Britton Anderson (