Mortgage Call Reports – FREE Information Kit, Deadlines, Workshops, and FAQs

Filing deadline for the first quarter 2011 was on May 15, 2011. However, updates to the NML took place on Saturday, May 14, 2011, and that update may have affected the ability to file. It is likely that there will be some leeway by the relevant regulatory agencies - but not an obligation - to permit late filers to avoid administrative penalties if the MCR filing takes place within the next few days. The MCR filing must be done even if the company did not conduct any residential mortgage loan activity during the reporting period.

   

• FAQs - Mortgage Call Reports - Article, by Jonathan Foxx
• Privacy Guidelines of NMLS - Synopsis, by Jonathan Foxx
• NMLS Library Section of Lenders Compliance Group
• Navigation Guide for Mortgage Call Reports
• Mortgage Call Report Basics
• Amending the Mortgage Call Report
• Requirements by Jurisdiction
• Practice Worksheet - Standard
• Field Definitions
• Expanded Section - Instructions
• Examples: Wholesale Lender, Retail Lender, Reverses Lender, Mortgage Broker
• Suite of Services - Lenders Compliance Group
• NMLS Users Forum - Sponsored by Lenders Compliance Group
  
  

DEADLINES FOR MORTGAGE CALL REPORT

Residential Mortgage Loan Activity
Due quarterly, within 45 days after every calendar quarter:

• Quarter 1 data (January 1-March 31) is due May 15
• Quarter 2 data (April 1- June 30) is due August 14
• Quarter 3 data (July 1-September 30) is due November 14
• Quarter 4 data (October 1-December 31) is due February 14

Financial Condition
Due annually, within 90 days of company’s Fiscal Year End

SOME FAQS

01Q: Am I required to file the Mortgage Call Report?

A: The Mortgage Call Report must be filed by all licensed Mortgage Brokers, Mortgage Bankers, Wholesale Lenders, Retail Lenders, and companies who make, service, or broker loans secured by residential real estate. The report must also be filed by all exempt companies who employ licensed mortgage loan originators. The report must be filed whether or not any business has been conducted under the license. 

02Q: Do branch offices and originators have to file the Mortgage Call Report?

A: No. The Mortgage Call Report is filed by the Mortgage Broker and Consumer Loan Companies and covers activities for branch offices and originators.

03Q: Do consumer loan licensees who make personal property loans have to file the Mortgage Call Report?

A: No. The Mortgage Call Report must be filed by licensees who make, service or broker loans secured by residential real estate.

04Q: When and what information do companies submit on the Mortgage Call Report if their fiscal year is not a calendar year?

A: The Mortgage Call Report must be submitted within 45 days of the end of the calendar quarter, not a company’s fiscal quarter. The activity information must reflect the data from the calendar quarter.

05Q: Is there a cost for submitting the NMLS Mortgage Call Report?

A: A processing fee will not be imposed in 2011 for filing the Mortgage Call Report. A decision is expected later in the year about any processing fees associated with filing the Mortgage Call Reports for 2012.

06Q: My company operates in multiple states. Do I file the NMLS Mortgage Call Report for each state?

A: Only one Mortgage Call Report is filed per company per quarter. This report includes break out data for each state in which the company is licensed or has licensed mortgage loan originators.

07Q: If I am an approved Fannie Mae or Freddie Mac Seller/Servicer or a Ginnie Mae Issuer but I currently don’t service any loans or issue mortgage pools, do I have to complete the Mortgage Call Report?

A: All state licensed companies or companies employing state licensed MLOs must complete the Mortgage Call Report even if they have had no activity during the reporting period. Companies that did not have activity during a particular quarter will be able to indicate this on the Mortgage Call Report. The system will require companies that have indicated on the MU1 Other Business Section that they are an approved Fannie Mae or Freddie Mac Seller/Servicer or Ginnie Mae Issuer to complete the Expanded Mortgage Call Report.

08Q: I am an approved Fannie Mae or Freddie Mac Seller/Servicer or a Ginnie Mae Issue but I currently do not complete the Mortgage Bankers' Financial Reporting Form (MBFRF), do I have to complete the Mortgage Call Report?

A: All state licensed companies or companies employing state licensed MLOs must complete the Mortgage Call Report even if they have had no activity during the reporting period or have not completed the Mortgage Bankers' Financial Reporting Form (MBFRF). If your state licensed company (or you are a company employing state licensed MLOs) is a Fannie Mae or Freddie Mac Seller/Servicer or Ginnie Mae Issuer, you must file the Expanded Mortgage Call Report. Companies that did not have activity during a particular quarter will be able to indicate this on the Mortgage Call Report.

09Q: I am a state licensed subsidiary of a federally regulated institution. Do I have to complete the Mortgage Call Report?

A: All state-licensed companies or companies employing state-licensed MLOs must complete the Mortgage Call Report.

10Q: If my institution is only federally-registered on NMLS and we only employ federally-registered MLOs, must we submit the Mortgage Call Report?

A: Currently only state-licensed companies and companies employing state-licensed MLOs must complete the Mortgage Call Report.

11Q: What do I include in the Broker Fee and Lender Fee fields of Residential Mortgage Loan Activity (RMLA) Section I?

A: Include all fees that your company has collected and retained. Examples include, but are not limited to, origination fees, application fees, servicing release premiums (SRP), and yield spread premiums (YSP). Do not include pass through fees. Note that compensation paid to MLOs is not considered a pass through fee.

12Q: How do I report my MLOs on the Mortgage Call Report?

A: You must enter the NMLS ID of the MLO along with the dollar amount and count of the residential loans that MLO closed during the reporting period. If the MLO had no activity, you would enter zeroes in the amount and count fields but the MLO must be listed for each state they hold a license.

13Q: What if my company had no MLOs during the reporting period?

A: When making the Mortgage Call Report filing, you will have the opportunity to enter information for any of your state licensed MLOs. If you do not have any state licensed MLOs during a reporting period, you would leave this section blank and attest to the filing before submission.

14Q: How do we report warehouse lines of credit?

A: Currently, you must list your warehouse lines of credit on each Residential Mortgage Loan Activity (RMLA) component. While each Residential Mortgage Loan Activity (RMLA) component is reported by state, the lines of credit should reflect all lines of credit the company holds.

15Q: Will the Mortgage Call Report be made available to the public?

A: Company specific reports will not be made publicly available. Aggregate data may be released to the public at a future date.

16Q: What happens to my data once it is submitted?

A: NMLS will process the data and release reports to state regulators on the submitted data. State regulators may also review individual company Mortgage Call Report filings within the system.

17Q: What amount do I report under the application amount, the initial amount on the application or the amount the application closes if it changes?

A: The initial amount on the application should be used when completing the Application data in the Mortgage Call Report.

18Q: What do you mean by “application” for the Mortgage Call Report?

A: Application is defined in the Mortgage Call Report as “an oral or written request for a home purchase loan, a home improvement loan, or a refinancing that is made in accordance with procedures used by a financial institution for the type of credit requested.” The Mortgage Call Report primarily relies on the Regulation B (ECOA) use and definition of application and generally follows Regulation C (HMDA) reporting requirements.

19Q: What happens if we do not file an Mortgage Call Report?

A: A company will be denied license renewal if any quarterly Mortgage Call Report filing is missing or if there are any related administrative penalties still outstanding.

20Q: Is the reporting activity information on the Residential Mortgage Loan Activity (RMLA) component by state based on the location of the property?

A: Yes, the activity information is based on the location of the property and reported by state.

More FAQs from NMLS

WORKSHOPS

At this time, only one NMLS-sponsored workshop is offered:

Monday, June 6, 2011 from 1:00 - 2:30 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.

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.

 Description

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

 Presenters

 

-Tim Lange, Senior Director - Policy, State Regulatory Registry LLC
-State Mortgage Regulators, TBD
 

 Cost

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.

THE DIAL-IN NUMBER AND WEBINAR LINK WILL BE EMAILED TO REGISTRANTS 2 DAYS BEFORE THE WORKSHOP.

 Visit Library

Nationwide Mortgage Licensing System & Registry
Library Section

NMLS Privacy Guidelines

In the course of working with our clients on their licensing and registration compliance, the question often comes up about the confidentiality of nonpublic personal information that is stored in the Nationwide Mortgage Licensing System Registry (NMLS).  

Additionally, we are asked who may obtain access to an Mortgage Loan Originator's (MLO's) confidential information.

Indeed, this question has come up several times in the NMLS Users Forum that we recently created in the following web spaces:

• LinkedIn
• Facebook
• Twitter
• Website

It is essential to know the NMLS privacy guidelines. Some information is available on the NMLS website, but not enough, and it is too condensed or insufficiently available.

We have prepared a 2-page Privacy Guidelines synopsis of the NMLS privacy guidelines. 

Available in our Library.

 

 AUTHORITY

The information in the NMLS is maintained to support regulatory supervision while providing the general public with access to certain information.

Privacy guidelines, in general, are based on the provisions of the Privacy Act of 1974 [5 U.S.C. 552a], as amended, which must be implemented by the NMLS. The authority to maintain the  NMLS and its privacy protocols comes from Section 1507 of the Secure and Fair Enforcement for Mortgage Licensing Act (S.A.F.E. Act) [12 U.S.C. 5106]. 

CATEGORIES OF RECORDS

The guidelines apply to any persons required by the S.A.F.E. Act to register in or license through the NMLS to obtain unique identifiers, and to maintain their registrations and licenses.

NMLS contains information documenting identity, including name and former names, social security number, gender, date of birth, and place of birth; home and business contact information; the date on which the MLO becomes an employee with the institution; criminal history, including the results of a background check; financial services-related employment history; civil, arbitration, regulatory, and disciplinary actions arising out of the MLO's financial services; and licensure revocations and suspensions. 

DISCLOSURE OF CONFIDENTIAL INFORMATION

Under the Privacy Act [5 U.S.C. 552a (b)], all or a portion of the records or information contained in the NMLS may be disclosed to:

• The appropriate federal, state, local, foreign, or self-regulatory organization or agency responsible for investigating, prosecuting, enforcing, implementing, issuing or carrying out a statute, rule, regulation, order, policy or license if the information may be relevant to a potential violation of civil or criminal law, rule, regulation, order, policy or license.

• A federal agency in the executive, legislative, or judicial branch of government, or to a Federal Reserve Bank, in connection with the hiring, retaining, or assigning of an employee, the issuance of a security clearance, the conducting of a security or suitability investigation of an individual, the classifying of jobs, the letting of a contract, the issuance of a license, grant, or other benefits by the receiving entity, or the lawful statutory, administrative, or investigative purpose of the receiving entity to the extent that the information is relevant and necessary to the receiving entity's decision on the matter.

• The Department of Justice, a court, an adjudicative body or administrative tribunal, a party in litigation, or a witness if the MLO's regulator determines, in its sole discretion, that the information is relevant and necessary to the matter.

• A congressional office in response to an inquiry from the congressional office made at the request of the individual to whom the record pertains.

• Contractors, agents, or others performing work on a contract, service, cooperative agreement, or activity for the MLO's regulator and who have a need to access the information in the performance of their duties or activities for the MLO's regulator.

• Appropriate federal, state, local authorities, and other entities when (a) it is suspected or confirmed that the security or confidentiality of information in the system has been compromised; (b) there is a risk of harm to economic or property interests, identity theft or fraud, or harm to the security or integrity of this system or other systems or programs that rely upon the compromised information; and (c) the disclosure is made to such agencies, entities, and persons who are reasonably necessary to assist in efforts to respond to the suspected or confirmed compromise and prevent, minimize, or remedy such harm.

• Depository and financial institutions or their subsidiaries or institutions regulated by the MLO's regulator for use in registering employees as MLOs or renewing employee registrations.

• Third parties when the information relates to the employment history of, and publically adjudicated disciplinary and enforcement actions against, loan originators that is included in the NMLS for access by the public in accordance with Section 1507 of the S.A.F.E. Act. (Cited Above)
  

OTHER RECORDS

• Nonpublic personal information of MLOs, including confidential information submitted by the MLO's regulator.

• Nonpublic personal information and confidential information required to establish an account.

• Nonpublic personal information and confidential information to verify the identity of anyone who contacts the NMLS.

• Information provided by regulators and MLOs that are used by the regulators to issue and maintain a state license or monitor a federal registration, including:

license status

application approvals

denials

regulator's and MLO's updates

• Collection and disbursement information regarding state license fees, registration fees, system processing fees, and information to process payment transactions.
  

RECORD RETENTION

Records are stored in electronic media and retrieved by an individual MLO's name or unique identification number and by the financial institution's name.

Information in NMLS is kept for a minimum of five years after the MLO no longer holds a valid state license or registration that is maintained in NMLS.

Visit Library

Privacy Guidelines of Nationwide Mortgage Licensing System Registry (NMLSR) -
Synopsis
Lenders Compliance Group
March 14, 2011