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 (banderson@csbs.org).  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 (banderson@csbs.org).

2017 Late CE Catalog Information Posted

NMLS has updated its Notice on Submitting Late CE Courses for the new catalog to be posted on January 2, 2017.   Late CE courses are those courses that an MLO is required to complete to make-up a previous year’s CE requirement.  The upcoming catalog will satisfy outstanding CE requirements for years 2010 through 2016.  Courses considered for the Late CE catalog are required to be a duplicate of currently approved courses which have a specific course number and offering so that credit can be retroactively applied to a previous year.

For a course to qualify for the Late CE catalog, the already approved course, or “parent” course, must be NMLS approved before it can be submitted for the Late CE catalog. The last day the “parent” course can be approved and eligible for the Late CE catalog is October 31, 2016. Note: there are no exceptions to the October 31 deadline.  Initial reviews take 15-20 business days and often require revisions and another review cycle. Allow ample time for the course review process (both content and technical).

Active Late CE courses that were approved for the 2016 catalog may be renewed between December 1-15 for entry into the 2017 Late CE catalog, so long as the course content is current and the “parent” course is active and in good standing.

The notice details how Late CE courses are administered and the number and types of courses that are required to be included in the catalog, and is available on the NMLS Education Policies page of the Resource Center.  Course providers seeking to participate in the Late CE catalog must meet the deadlines and other criteria as detailed in the notice.

Questions regarding Late CE courses should be directed to Jessica Esquina (jesquina@csbs.org).

New Education Notice Posted for Florida

NMLS approved course providers are advised that a new State-Specific Education Notice has been posted for Florida. Effective January 1, 2017, FL will require 2hrs of NMLS approved state-specific PE. Additionally, MLO’s licensed in the state will also be required to complete 1 hour of FL-specific CE as a condition to renew their license for 2018. The new requirements are in response to Florida’s adoption of the Uniform State Test (UST).

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


CO PE Course Content Outline Updated

CO-DORA has updated the course content for the required 2 hours of pre-licensure education.  The outline has been updated to reflect recent changes approved by the Colorado Board of Mortgage Loan Originators to state specific regulation to comply with the federal integrated disclosure rules. Changes reflected in the course content outline include:

  • Strike all of CRS 12-61-914(2)- Written Disclosure of Fees
  • Strike all of CRS 38-40-102- Disclosure of Cost
  • Moved all deceptive practices from 12-61-911 to 12-61-905.5- Prohibited Conduct and Deceptive Practices
  • Strike all of 12-61-911- Prohibited Conduct

The revised content outline has been posted on the course provider page of the NMLS Resource Center.  It is requested that CO state-specific PE courses by updated no later than July 15, 2016 or upon course renewal, whichever is soonest.

Course Approvals – Ready, Set…uh Wait?

Help Us Help You!  We’re encountering a problem where some providers are initiating course approval or renewal projects in the Education Management System (EMS) but then are not submitting the course content until several weeks later.   This practice is negatively impacting the time it takes for courses to get approved.

As a rule you should only submit new courses for approval/renewal when the course content is ready to be reviewed.  Within 24 hours of the fees being paid in the EMS a project is created in the content portal (Basecamp) and the content should then be uploaded and made available for the course evaluator.  If the content is not there we reassign the evaluator to another project and they only revisit the course at their next window of availability.  Bottom line: not having content ready means your course(s) will go to the bottom of the work queue and this could have a serious impact if the course is up for renewal.

Additionally, if you are intending to submit a large number of courses for approval (5 or more), please give us a head’s-up by sending an e-mail to Britton (banderson@csbs.org).  Just like you we’re trying to manage our resources as efficiently as possible so if we know there are going to be a large number of courses coming in so we can plan accordingly.