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.