From the Desk of the ‘Om-Bobs-man’
"Om-Bobs-Man" is the nickname Bob Niemi earned while serving as the NMLS Ombudsman in 2014 and 2015. Bob is a former Ohio state regulator and now an expert consultant on NMLS and state regulatory matters. Bob can be reached at BNiemi@Bradley.com.
Deadlines, Deadlines, Deadlines…
N
ovember is the month we give thanks and remember our Veterans; it is also the month of renewals in the NMLS. For those who are actively deployed, many states have processes and regulations in place to provide benefits to active duty and veterans of the United States Armed Forces and National Guard of any state. More details on those programs can be found by searching on the NMLS Resource Center or checking with your home state agency. For the rest of us, November is NMLS Renewal Period and lasts from one to ninety days and sometimes more. While the most common timeframe for renewals is from November 1st through December 31st, there are a few states with shorter periods. There are also a few other states with stricter guidelines for renewals. Condensed Renewals If you do business in West Virginia, hopefully your renewal is already in process. While not a hard deadline, renewal requests submitted after November 2nd may not be approved before the end of the year. The challenge to a late renewal is that if the
renewal has not been approved, all activity in the New Year must cease until the renewal has been approved. Similar issues will impact companies in Idaho, Iowa, Kansas, Wyoming, and some Vermont mortgage licenses. This is not an exclusive list. Their December 1st submission date is to guarantee a review prior to year-end to prevent a cessation in mortgage activities until the license renewal is approved. But note that the Kansas renewal deadline is by statute. So, please double check that renewal. December 15th brings more states into the mix with Minnesota and Washington. Some states like Wyoming and Minnesota do not allow a company to operate in the New Year even if the renewal request was submitted within the renewal period but not approved prior to the end of the year. No one wants to send the email notification that your originators must cease all business activities in a state until the renewal has been approved. Yes, that is another reason to double check that your renewals have all been requested.
The MORTGAGE BANKER Magazine
45
November 2020
Reinstatement Some states do offer reinstatement with added fees, but not all states. Iowa has a December 1st submission, and late submissions must be approved by December 31st for lenders to operate in the New Year. Further, there is no reinstatement and companies who fail to submit a renewal by December 31st are moved to terminated-expired status. These companies would begin with a new license submission. But no one is picking on Iowa since similar circumstances exist in Idaho, Illinois, New Hampshire, South Dakota, and West Virginia. Now, if you believe that this is enough already, consider your continuing education deadlines. Georgia’s state specific education must be completed by Halloween. Washington, D.C. and West Virginia provide one more day to November 1st. There are five more states that have December 1st for their education completion deadline. Give thanks that all this is available on the NMLS Annual Renewal Page at www. nationsidelicensing.org. MBM
