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It’s Fall, But Not Fail…

Fright doesn't end after Halloween with NMLS renewal season fast approaching.

Bob Niemi
Insider
Bob Niemi
A row of NMLS regulators wait in dark silhouette.

Yes, fall has returned once again. The changing of the leaves and cooler temperatures reminds us that it is time for… Renewals. NMLS Renewals in the second year of working remote may or may not be scarier than Halloween. These both occur almost at the same time and that can bring ghosts and goblin-like behavior when trying to validate the production staff and their renewal requirements. Mortgage originators may soon find that there could more tricks than treats as Halloween fades into Renewal Season.

The NMLS Renewal Period is already short at only 61 days beginning on November 1 and ending on December 31, not to mention the holidays and holiday festivities. But there are some states that have earlier filing deadlines, such as Minnesota and West Virginia, allowing only a day or so for renewals. This is a short window for renewal submissions but also licenses that have not been approved by December 31st must discontinue mortgage activity until the renewal has been approved. Talk about scary!

Longer and longer lists of state specific continuing education hours have grown in recent years so now is the time of the year to triple check that everyone on your team is ready for renewal. Many states will also require mortgage originators to get updated criminal background checks, such as Connecticut and Kentucky this year. Updated credit reports will also be required by many states, adding to the list of items that could delay a timely renewal.

Companies that do business in Delaware, Hawaii, Idaho, Iowa, Kansas, Wyoming, and Vermont need to check the NMLS Annual Renewal Information page for similar dates. The webpage contains valuable resources, renewal checklists, and a detailed chart that summarizes these renewal deadlines, fees and more. All this and training as well are available via the NMLS Resource Center. 

Now, fall is also a time of year overloaded with distractions and official and unofficial holidays. Hopefully New Year’s Day is cause for celebration and not a company shutdown. This could happen as many states require that licenses must be approved as of January 1 to continue mortgage business in their state: Another reason to prepare now and file early.

Some states, like California and Oregon, allow for companies to apply for late reinstatement as late as February 28, but no business can be conducted between January 1st and the formal reinstatement. Reinstatement is preferred to applying for a new license, but not all states allow for this process and any state that does will charge additional fees. 

The hope of this endeavor is to submit all renewals on November 1 in anticipation of early approvals. However, the reality is that not all states will be able to review and approve in a short time. Working from home, staffing issues and the dramatic growth of licensees in the last few years will make this year a longer process than before. Do what you can now to avoid delays or surprises. Make your list and check it twice, then submit early!

This article was originally published in the Mortgage Banker October 2021 issue.
Bob Niemi
Bob Niemi

Bob Niemi is a senior advisor at Bradley Arant Boult Cummings LLP.

Published on
Oct 01, 2021
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