Tuesday, April 26, 2011

The Smoking Gun - Loan Originator Compensation

Jonathan Foxx is a former Chief Compliance Officer of two publicly traded financial institutions, and the President and Managing Director of Lenders Compliance Group, the nation’s first full-service, mortgage risk management firm in the country.

On April 6, 2011, the TILA loan originator compensation rule (Rule) went into effect, despite the best efforts of numerous industry organizations, a federal agency, congressional legislators, and private citizens to prevent such implementation. Although the NAIHP has withdrawn its appeals case in order to pursue other options, the NAMB continues its legal challenge in the US Court of Appeals - DC.
A week before the April 1, 2011 statutorily effective date a letter was written to FRB Chairman Bernanke, requesting significant revisions to the Rule - revisions that strike at critical issues contained in the NAIHP and NAMB's objections.
Commentary and Outline
This Commentary offers a brief outline. I am leaving out citations, where possible, for ease of reading. This outline is not meant to be comprehensive, authoritative, or relied upon for legal advice. It offers only a brief synopsis of the argumentation. For citations, exhibits, and argumentation, please read the letter. (See below.)
The word that is heard perishes, but the letter that is written remains.
- Ancient Proverb
On March 24, 2011, Barnie Frank (D-MA), the House's counterpart to the Senate's Christopher Dodd (D-CT) - now former Senator Dodd - wrote a letter to Chairman Bernanke requesting revisions to the FRB's implementation of the Rule.
Why Frank sent this letter to the FRB eight months after the enactment of his eponymously named legislation known as the Dodd-Frank Act (DFA) - otherwise known as the Wall Street Reform and Consumer Protection Act - after the commencement of litigation, after most of the mortgage industry leadership had spoken with many elected officials in congress to prevent implementation, after the SBA Office of Advocacy had requested a delay, after key organizations had lobbied all along against the Rule, and just days before the effective compliance date - why, that is, Mr. Frank decided to send this letter at the last minute, as it were, is anybody's guess.
Perhaps we can venture a guess or surmise some possible motives.

But, let's review the letter.
Post Separator-2-LCG
A letter does not blush.
- Marcus Tulius Cicero
In the letter, Mr. Frank wants the Rule to go into effect, but he would like the Rule amended "immediately thereafter" for two changes. How a federal statute affecting an entire industry can go into effect and then immediately thereafter not go into effect - that he does not say.
According to Mr. Frank, who is now the Ranking Member of the House Financial Services Committee, the Rule "go[es] beyond what was required" and the "two problems unnecessarily interfere with borrowers' ability to obtain loans from mortgage brokers," and revising the Rule accordingly "would not damage the core underlying consumer protections."
Yes, of course, the cited provisions are "problems" - precisely so.
Nevertheless, Mr. Frank believes:
"It is important that the rule take effect as scheduled, and that the Federal Reserve take immediate action to correct the two problems created by the rule."
Post Separator-2-LCG
Problem # 1
The Rule "appears" to prohibit a mortgage brokerage firm that is receiving compensation for a loan from the consumer from paying any compensation related to that loan to an employee of that firm.
According to Frank, this is because the rule:
"appears to include language that states that when a loan originator receives compensation from the consumer on a loan, no loan originator at all can receive compensation related to that loan from any source."
This interpretation differs from Section 1403 of the DFA, which "merely states" that if a loan originator receives compensation from the consumer, that originator cannot receive compensation from another source.
Frank avers that this statutory provision is meant to prevent "double dipping." However, the FRB's Rule is "more restrictive" because it prevents the sharing of the consumer-paid compensation by the firm with an employee for that employee's work on the loan.
Stating the obvious, Frank continues:
"I would note that such sharing of compensation would not involve an increase, directly or indirectly, in the level of fees paid by the consumer."
Here's his recommended change:
The language should be revised to allow employee compensation in this circumstance.
Post Separator-2-LCG
Problem # 2
Referring to - but not specifically stating - the Rule's requirements regarding the restrictions on making small fee reductions at loan closing to cover shortfalls which sometimes result because of last minute third party fee changes, or to cover the cost of a short extension of a loan lock when the loan failed to close within the window of the original loan lock, Mr. Frank thinks that the Rule is too restrictive.
Here's his recommended change:
The practice should be allowed (1) if the fee reduction is at the request of the borrower and is made within a short period (i.e., 24 hours) of the loan closing, and (2) if limited by frequency of such use, implemented through either the dollar or percentage amount of the reduction.
Post Separator-2-LCG
Festina Lente (More Haste, Less Speed)
- Ancient Latin Proverb
Mr. Frank's one-and-a-half page epistle to Chairman Bernanke ends as abruptly and politely as it begins, with these words:
"I believe that both of these provisions should be revised expeditiously by the Federal Reserve through an appropriate action or proceeding at the earliest possible time. Thank you for your consideration of these requests."
Post Separator-2-LCG
Guess, if you can, and choose, if you dare.
- Pierre Corneille
So, why this letter? It is not as if the FRB has a history of abiding by the requests of Congress. Recently, in fact, it took an Act of Congress to pry the FRB's financial data about distribution of "bail-out" funds from the FRB's closeted grasp.
And, at the time of the letter's writing, the FRB was already embroiled in resisting a stay of the Rule. Given the timing, is it really likely that the FRB would have been willing to change course on the basis of Frank's requests? I think not.
Ascertaining motive is always a very elusive undertaking.
In determining what sector of the mortgage origination industry benefits most and is best protected by Mr. Frank's recommended changes to the Rule, it is a good idea to follow the money - in more ways than one!
What do you think?
Please Leave Your Comments Below!

Monday, April 25, 2011

FAQs Outline - Loan Originator Compensation (260 Q&As - 71 Pages!)

The most comprehensive Questions and Answers analysis is now available:

FAQs Outline - Loan Originator Compensation

Update: April 25, 2011

The FAQs Outline covers virtually all areas affected by the amendment to the Truth in Lending Act (TILA), as it relates to loan originator compensation and anti-steering provisions and much more!

Post Separator-2-LCG
FAQs Outline
Loan Originator Compensation

260 Questions and Answers
71 Pages
12 Months Updates Included
Email Notification for Updates
Download Directly from Secure Portal 

Learn More(1)
                FAQs Outline: $125    
Post Separator-2-LCG

Thursday, April 21, 2011

Ability to Repay - Additional Analysis

In our Tuesday (4/19/11) newsletter and also in our post we notified you of the FRB's proposed amendments to Regulation Z that would set out how residential mortgage lenders would be required to determine a consumer's ability to repay a mortgage (Proposal). 
The Proposal would define what are termed "qualified mortgages" and also set minimum underwriting standards for many mortgages.
The proposed amendments, which are required by the Dodd-Frank Act (DFA), also would implement limits on prepayment penalties and attempt to prevent lenders from evading the rules.
In today's review, we will provide further analysis of the Proposal.
Comment Period: Until July 22, 2011.
Because the Consumer Financial Protection Bureau (CFPB) will take over Regulation Z rulemaking authority on July 21, 2011, the FRB has said that it will not be taking final action on the proposal and that the comments it receives will be transferred to the CFPB.
Loan Products
The Proposal would apply the ability-to-repay requirement to nearly any consumer credit plan secured by a dwelling, but it would exclude open-end credit plans, reverse mortgages, construction or other temporary loans with terms of 12 months or less, and timeshare plans. 
The FRB claims that the proposed requirements are similar to those it adopted for higher-priced mortgages in July 2008 under the Home Ownership and Equity Protection Act (HOEPA), but they would apply to mortgages that are not higher-priced and those that are not secured by the consumer's principal dwelling.
Ability to Repay
The DFA prohibits a lender from making a mortgage loan unless it has made "a reasonable and good faith determination, based on verified and documented information, that the consumer will have a reasonable ability to repay the loan, including any mortgage-related obligations." Examples of "mortgage-related obligations" are property taxes and homeowners' association assessments.
Post Separator-2-LCG
8 Criteria
A consumer's individual ability to repay uses 8 criteria:
  1. the income or assets the lender is relying on in making its decision;
  2. the consumer's current employment status;
  3. the mortgage's monthly payment;
  4. the monthly payment on any other mortgages on the property, such as home equity lines of credit;
  5. the monthly payment for all mortgage-related obligations;
  6. the consumer's other current debt obligations;
  7. the consumer's monthly debt-to-income ratio or residual income; and
  8. the consumer's credit history.
Post Separator-2-LCG
Special Features
If the mortgage includes an adjustable interest rate, it must be underwritten based on the fully indexed interest rate, or based on the introductory rate if that is higher than the fully indexed rate.
Features such as balloon payments, interest-only payments and negative amortization would not be prohibited. However, there would be strict underwriting standards.
Post Separator-2-LCG
Refinancing: "Nonstandard" into a "Standard" Mortgage
The lender is required to consider and verify the consumer's income and assets, if the lender is refinancing a mortgage loan and also adding certain features to the loan, such as a balloon payment, negative amortization, or interest-only payments. Notwithstanding this requirement, all the other aforementioned criteria must be considered.
The consumer must qualify for the loan based on the highest interest rate that could be imposed in the first five years after consummation, rather than over the life of the loan. There would be a requirement to satisfy limits on points and fees and the loan must materially reduce the consumer's monthly payments. Importantly, the refinancing option would be available only if the consumer is not delinquent under the existing mortgage.
Post Separator-2-LCG
Qualified Balloon Loan - Rural or Underserved Area
Some balloon loans would be considered to be qualified mortgages in rural and underserved areas. These loans would not only comply with all of the other criteria for a qualified mortgage but also would need to be underwritten based on scheduled payments other than the balloon.
Post Separator-2-LCG
Prepayment Penalties
The DFA provides limits on prepayment penalties. A prepayment penalty would be permitted only in the case of a prime, fixed-rate mortgage that meets the criteria for being a qualified mortgage.
The amount of the permitted penalty would decrease with the passage of time; for instance, a 3% penalty would be permitted in the first year of the loan, a 2% penalty in the second year, and a 1% penalty in the third year.
No penalty would be permitted more than three years after the loan was consummated. A lender that offers a consumer a loan with a prepayment penalty would also be required to offer a loan without that feature.
Post Separator-2-LCG
Safe Harbor or Rebuttable Presumption
Meeting the requirements of the "qualified mortgage" would provide the lender with some protection from liability. However, the DFA is actually not clear as to whether the consequent protection was intended to be a safe harbor from liability or only a means to provide a rebuttable presumption that the lender had complied with the ability to repay mandates.
Thus, the Proposal offers these two "alternatives" toward resolving the uncertainty vis-a-vis a "qualified mortgage:"
1. Safe Harbor Alternative: The loan would not permit negative amortization, interest-only payments, or balloon payments; the loan term would not exceed 30 years; the points and fees would not exceed 3 percent of the total loan amount; the consumer's income and assets would be documented and verified; and, the loan would be underwritten based on the maximum interest rate in the first five years, using a fully-amortizing payment schedule and considering any mortgage-related obligations.
2. Rebuttable Presumption Alternative: Includes the Safe Harbor Alternative and adds a requirement for the lender to consider and verify the monthly payment of any simultaneous mortgage and the consumer's employment, other current debt obligations, debt-to-income ratio or residual income, and credit history.
Post Separator-2-LCG
Lender Liability
The DFA provides that violations of the ability to repay requirements face tripartite penalties: (1) damages consisting of the sum of all finance charges and fees paid by the consumer, (2) the consumer's actual damages, and (3) described statutory damages.
A consumer could file a claim at any time within three years of the violation, although the consumer could assert the violation as a set-off or recoupment in a foreclosure suit at any time.
Visit Library
Law Library Image
FRB: Ability-to-Repay, Proposed Rule - Notice
April 18, 2011

Tuesday, April 19, 2011

FRB: Proposes Rule - Ability to Repay

Today, the Federal Reserve Board (FRB) requested public comment on a proposed rule under Regulation Z that would require creditors to determine a consumer's ability to repay a mortgage before making the loan and would establish minimum mortgage underwriting standards.
The FRB notice was issued on April 18, 2011.
The revisions to the regulation, which implements the Truth in Lending Act (TILA), are being made pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (DFA).
The proposal would apply to all consumer mortgages (except home equity lines of credit, timeshare plans, reverse mortgages, or temporary loans).
The proposal would also implement the Dodd-Frank Act's limits on prepayment penalties.
Comment Period: Until July 22, 2011.
Because the general rulemaking authority for TILA is scheduled to transfer to the Consumer Financial Protection Bureau on July 21, 2011. 
Accordingly, this rulemaking will not be finalized by the FRB.
Four Compliance Options
Consistent with the DFA, the proposal would provide four options for complying with the ability-to-repay requirement.
General Ability-to-Repay Standard - Option # 1
First, a creditor can meet the general ability-to-repay standard by considering and verifying specified underwriting factors, such as the consumer's income or assets.
Considering and verifying the following eight underwriting factors:
  • Income or assets relied upon in making the ability-to-repay determination
  • Current employment status
  • The monthly payment on the mortgage
  • The monthly payment on any simultaneous mortgage
  • The monthly payment for mortgage-related obligations
  • Current debt obligations
  • The monthly debt-to-income ratio, or residual income
  • Credit history
Additionally, the underwriting of the payment for an adjustable-rate mortgage would be based on the fully indexed rate.
Post Separator-2-LCG
Qualified Mortgage - Option # 2
Second, a creditor can make a "qualified mortgage," which provides the creditor with special protection from liability provided the loan does not have certain features, such as negative amortization; the fees are within specified limits; and the creditor underwrites the mortgage payment using the maximum interest rate in the first five years. 
The FRB seeks comments on two alternative approaches for defining a "qualified mortgage."
Two alternative definitions of a "qualified mortgage."
Alternative 1
Alternative 1 would operate as a legal safe harbor and define a "qualified mortgage" as a mortgage for which:
  • The loan does not contain negative amortization, interest-only payments, or a balloon payment, or a loan term exceeding 30 years;
  • The total points and fees do not exceed 3 percent of the total loan amount;
  • The income or assets relied upon in making the ability-to-repay determination are considered and verified; and
  • The underwriting of the mortgage (1) is based on the maximum interest rate that may apply in the first five years, (2) uses a payment scheduled that fully amortizes the loan over the loan term, and (3) takes into account any mortgage-related obligations.
Alternative 2
Alternative 2 would provide a rebuttable presumption of compliance and would define a "qualified mortgage" as including the criteria listed under Alternative 1 as well as additional underwriting requirements from the general ability-to-repay standard.
The creditor would also have to consider and verify:
  • The consumer's employment status,
  • The monthly payment for any simultaneous mortgage,
  • The consumer's current debt obligations,
  • The monthly debt-to-income ratio or residual income, and
  • The consumer's credit history.
Post Separator-2-LCG
Balloon-Payment Qualified Mortgage - Option # 3
Third, a creditor operating predominantly in rural or underserved areas can make a balloon-payment qualified mortgage. This option is meant to preserve access to credit for consumers located in rural or underserved areas where banks originate balloon loans to hedge against interest rate risk for loans held in portfolio.
Under this option, a creditor can make a balloon-payment qualified mortgage with a loan term of five years or more by:
  • Complying with the requirements for a qualified mortgage; and
  • Underwriting the mortgage based on the scheduled payment, except for the balloon payment.
Post Separator-2-LCG
Refinancing of a Non-Standard Mortgage - Option # 4
Fourth, a creditor can refinance a "non-standard mortgage" with risky features into a more stable "standard mortgage" with a lower monthly payment. This option is meant to preserve access to streamlined refinancings.
Under this option, a creditor complies by:
  • Refinancing the consumer into a "standard mortgage" that has limits on loan fees and that does not contain certain features such as negative amortization, interest-only payments, or a balloon payment;
  • Considering and verifying the underwriting factors listed in the general ability-to-repay standard, except the requirement to consider and verify the consumer's income or assets; and
  • Underwriting the "standard mortgage" based on the maximum interest rate that can apply in the first five years.
Post Separator-2-LCG
Other Rule Proposals
  • Implement the Dodd-Frank Act's limits on prepayment penalties
  • Lengthen the time creditors must retain records that evidence compliance with the ability-to-repay and prepayment penalty provisions
  • Prohibit evasion of the rule by structuring a closed-end extension of credit as an open-end plan
Visit Library
Law Library Image
FRB: Ability-to-Repay, Proposed Rule - Notice
April 18, 2011

Tuesday, April 12, 2011

First They Came For The Mortgage Brokers!

Jonathan Foxx is a former Chief Compliance Officer of two publicly traded financial institutions, and the President and Managing Director of Lenders Compliance Group, the nation’s first full-service, mortgage risk management firm in the country.

It is now one week since the U. S. Court of Appeals lifted the stay on the loan originator compensation amendment to TILA. Are we at the end or the beginning? Whether the stay of the TILA loan originator compensation rule (Rule) was lifted or remained, one thing is clear: virtually the entire mortgage industry has coalesced against it. 
The battle that I characterized as one between David and Goliath has been joined, with most market participants lining up behind David, and few behind Goliath.
Let's step back from the fray and give some thought to the broader implications.
Where We Are Now       
After nearly an entire industry has written letters, lobbied, and received support from virtually all industry trade associations; after certain U. S. Senators and a majority of the House Financial Services Committee asked the FRB for a delay in the Rule; after two major industry organizations, the NAMB and NAIHP, were constrained to file costly motions for a temporary restraining order and preliminary injunction; and after the U. S. District Court - DC denied that motion, thereby causing the NAMB and NAIHP to seek relief in the U. S Court of Appeals - DC, which granted a stay and then dissolved it just a few days later; finally, the mortgage industry's participants, at huge financial cost in preparation, moved forward April 6, 2011 in complying with the Rule's requirements.
The lawsuits continue in the Appeals Court, but some actors in the industry, particularly mortgage brokers, are now bracing for what they see as their economic ruin.
Post Separator-2-LCG
A Framework      
On August 16, 2010, the FRB issued a final rule to amend Regulation Z. This is the Rule that restricts loan originator compensation and steering practices, ostensibly to protect consumers in the mortgage market from unfair, abusive and deceptive lending practices.
Subsequently, the FRB set forth interpretive guidance in its rulemaking capacity, in order to implement Title XIV of the Dodd-Frank Act, titled the Mortgage Reform and Anti-Predatory Lending Act (Mortgage Act).
Many provisions of the new TILA mortgage originator compensation provision imposed by the Mortgage Act are similar to the Rule. The definition of loan originator in Regulation Z covers mortgage brokers, employees of creditors and mortgage brokers obtaining an extension of consumer credit for the mortgage lender, and applies to creditors making use of "table funding" by a third party. With some exceptions, the Rule applies to any consumer credit transaction secured by a consumer's dwelling, whether first or subordinate lien loans, and rests on the following framework:
Frame # 1: No loan originator compensation in connection with a consumer credit transaction may be based on the transaction's terms and conditions (i.e., interest rate or annual percentage rate), other than the amount of principal, unless the amounts are bona fide or reasonable third-party charges. The provision is directed at yield spread premiums (YSPs) paid by the creditor to the loan originator.
Frame # 2: In order to ensure that loan originators do not evade the consumer protection provision of Regulation Z, no loan originator may receive compensation from any person other than the consumer if the loan originator receives direct compensation payment from the consumer. The Rule establishes, therefore, a "one or the other" compensation scheme with respect to loan originator compensation for specific consumer credit transactions.
Frame # 3: No loan originator may direct or "steer" a consumer to consummate a consumer credit transaction secured by a dwelling based on the fact that the originator will receive greater compensation from the creditor in that transaction than in other transactions that the originator could have offered to the consumer, unless the consummated transaction is in the consumer's interest. The FRB provides a safe harbor rule intended to provide loan originators with clear guidance to ensure compliance with the anti-steering rule.
Post Separator-2-LCG
Lesser of Two Evils?
A basic presumption of the FRB is best left to the FRB to so state:
"The Board believes that compensation based on the amount of credit extended is less subject to manipulation by the originator than compensation based on terms such as the interest rate or prepayment penalties."
Thus, the FRB holds that limiting compensation to the loan amount is "less subject to manipulation" than basing compensation on the terms associated with the loan amount or loan type.
In effect, the FRB has determined that basing compensation on the loan amount is a lesser evil than basing it on the loan terms.
As but one example of the argument, mortgage brokers assert that the use of Yield Spread Premiums (YSPs) can help consumers cover closing costs including loan origination fees. However, the FRB maintains that YSPs can also serve as an incentive for mortgage brokers to steer consumers into higher interest rate loans; therefore, the Rule restricts the way in which YSPs may be used.
Mortgage brokers counter by highlighting the fact that they willingly disclose the YSPs, yet bankers and banks do not disclose their Service Release Premiums (SRPs) which they collect on higher interest rate loans sold to the secondary market.
Post Separator-2-LCG
YSP versus SRP
I have written extensively about the controversy involving the YSP and the SRP here, here, and here.
In fact, I have published remedies to resolving the controversy involving the YSP and consumer financial protection issues, such as my suggestion in July 2009 (PDF) to provide a credit to the consumer of the YSP and allowing the consumer to apportion it - a remedy, actually, that was later adopted in the RESPA reform provisions effective on January 1, 2010.
As a basis to the Rule, it seems the FRB contends that the consumer simply can't differentiate between compensating a mortgage broker for a higher interest rate loan through a YSP and compensating a banker or bank for a higher interest rate loan through an SRP.
States the FRB:
"Although consumers may reasonably expect creditors to compensate their own employees, consumers do not know how the loan officer's compensation is structured or that the loan officer can increase the creditor's interest rate or offer certain loan terms to increase their own compensation."
Such is the FRB's conclusion, notwithstanding due and fully articulated notice to the consumer. 
To make sense of this conclusion, one would have to assume the consumer just can't seem to figure out that an increased interest rate charged by a creditor receives concomitant compensation in some form qua SRP in the secondary market.
The fact that one form of compensation is disclosed to the consumer (YSP) and the other is not disclosed to the consumer (SRP) seems to be left out of the argument entirely.
Indeed, in the entire Dodd-Frank Act of 2,319 pages, the words "Service Release Premium" do not occur even once. But these words can be found:
"No provision ... shall be construed as
(A) permitting any yield spread premium or other similar compensation that would, for any residential mortgage loan, permit the total amount of direct and indirect compensation from all sources permitted to a mortgage originator to vary based on the terms of the loan (other than the amount of the principal) (My emphasis.)
(B) limiting or affecting the amount of compensation received by a creditor upon the sale of a consummated loan to a subsequent purchaser"
NOTE: Elided, intentionally or not, in (B) are the words "service release premium."
Post Separator-2-LCG
Thought Experiment
Now, let's consider some implications of the FRB's view, by indulging in a Thought Experiment.
Prior to August 6, 2011, a broker paid its loan officer employee on production of closed loans, which included terms and conditions. This compensation model, really, is one of the oldest financial models in economic theory. There is virtually no economic theory ever propounded - from Marxist to Capitalist - that does not recognize this particular model as a fundamental basis to incentive. It predates the ancient Greek Agora, or marketplace.
Of course, I'm referring to the Commission Model. This model applies to any transaction between parties to a financial transaction where incentive is associated with many aspects of production. It represents a fee charged by a broker or agent for services rendered in facilitating a financial transaction. For example, the commission model applies to insurance agents, real estate agents, securities brokers, financial advisers, car salespersons, shoe salespersons, broom salespersons - actually to any sales job that relies on commissioned income, in whole or in part, to sell a product or service.
Here's the question: is the consumer really unable to figure out that the compensation earned by a commissioned shoe salesperson is not of a piece with the compensation - part of which is "profit" - earned by the shoe store itself when the consumer buys shoes?
And, if not - if the consumer lacks the kind of discretion that has been fundamentally a part of market activity since the days of earliest recorded history - how and when was this discretion lost?
And if the consumer, having now lost this age-old ability that previously seems to have been ingrained in human nature - but, perhaps, apparently no more! - has to be protected, how is the consumer protected by de-incentivizing the shoe salesperson, yet preserving the profit incentives of the shoe store itself?
And, if the shoe store must re-incentivize the shoe salesperson by building into its price for shoes the cost to adequately compensate the shoe salesperson, how is this increased cost of doing business not passed onto the consumer in the form of higher priced shoes?
After all, the shoes still need to be sold, and bring a profit to all market participants - come what may!
Post Separator-2-LCG
The Unpredictable Future
The Thought Experiment given above, like all analogies, is not meant to be precise.
But it is suggestive of what may yet happen.
However we got here, we're here. But where do we go from here?
Or, better said, where does any commission-based industry go from here?

Monday, April 11, 2011

FAQs Outline - Loan Originator Compensation

The update to the most comprehensive Questions and Answers analysis is now available:

FAQs Outline - Loan Originator Compensation
Release Update: April 11, 2011

The FAQs Outline covers virtually all areas affected by the amendment to the Truth in Lending Act (TILA), as it relates to loan originator compensation. 

Post Separator-2-LCG
FAQs Outline
Loan Originator

210 Questions and Answers
55 Pages
12 Months Updates Included
Email Notification for Updates
Download Directly from Secure Portal
Learn More(1)
                FAQs Outline: $125    
Post Separator-2-LCG

Wednesday, April 6, 2011

Mortgage Call Report Workshop - NMLS Offers Training

The NMLS will provide training for the Mortgage Call Report 

Dates (Click to Register)

Wednesday, April 13, 2011 from 2:00 - 3:30 pm ET
Thursday, April 14, 2011 from 2:00 - 3:30 pm ET
Thursday, May 5, 2011 from 1:30 - 3:00 pm ET
Tuesday, May 10, 2011 from 1:30 - 3:00 pm ET

NOTE: In order to register for this event, you will need to create a login ID on the CSBS website.  You cannot use your NMLS login ID.
NMLS is sponsoring a professionally-moderated conference call and webinar for companies that wish to learn about the NMLS Mortgage Call Report.  The webinar will provide users with an overview of the requirements and "how to" for submitting a Mortgage Call Report in NMLS.
 What will participants learn?
  • Policies regarding who needs to submit the NMLS Mortgage Call Report and when
  • Directions on which portions of the Call Report need to be completed by different companies
  • Resources for completing the Call Report, such as field definitions
  • Overview of the XML option for uploading Call Report data into NMLS
  • How the Call Report data will be used by regulators
-Tim Lange, Senior Director - Policy, State Regulatory Registry LLC
-State Mortgage Regulators, TBD


The registration fee for this professionally-moderated workshop is $35, which entitles the registrant to one conference call dial-in and one webinar login for the audio and visual portions respectively.

 Visit Library

Law Library Image
Nationwide Mortgage Licensing System & Registry
Library Section