Don’t Get Caught By Surprise: NMLS Adds New Requirements in Connection with RenewalIf a company is keeping its Nationwide Multistate Licensing System (NMLS) record current, the renewal season should be a relatively painless exercise in fee collection. However, in addition to the normal renewal housekeeping measures, there are a few new twists to the 2016-2017 NMLS renewal process that you should be aware of so that you don’t get caught by surprise.

Everyone knows that the path to a smooth renewal lies in advance preparation. Compliance professionals know that they need to keep track of a multitude of items including, but not limited to: 1) identifying any outstanding license items early and making efforts to clear them; 2) being aware of early renewal submission deadlines to increase the chance of renewal being approved prior to year-end; 3) preparing to submit renewal fees via credit card to decrease any potential ACH transaction processing delays; and 4) continuing to monitor the NMLS for any additional requested items after renewal submissions have been made.

However, the NMLS has added three new functionalities in connection to the 2016-2017 renewal process that may catch you by surprise. To get ahead of the game, a company should make plans to complete these items now and not wait until the renewal window to open on November 1:

  1. Complete the conversion process to Electronic Surety Bonds (ESB) for certain licenses held with the Indiana Department of Financial Institutions, Iowa Division of Banking and Massachusetts Division of Banks. NMLS has recently released functionality to track ESB and these jurisdictions are requiring that the conversion of paper bonds to ESB take place in conjunction with renewal. While these agencies are not implementing ESB for all license types, mortgage, consumer finance and money transmission licenses are included. Visit the ESB Adoption Table here to view a complete list of licenses currently subject to ESB.
    Keep in mind that a licensee must first grant authority to the surety bond provider in the NMLS to issue the ESB. In order to complete the ESB conversion process in the NMLS, a control person, who is an officer of the company, will be required to attest to and submit the bond in the NMLS. If your company holds one of the licenses subject to ESB during the renewal window, start the conversion process early.
  2. Prepare MU2 control persons to be fingerprinted so that Criminal Background Checks (CBC) can be submitted through NMLS in connection with renewal. The NMLS has released functionality that allows MU2 control persons (including direct owners, executive officers, individual indirect owners, qualified individuals and non-licensed branch managers) to complete CBC through the NMLS in 26 currently participating states. While the requirement to submit a CBC through NMLS varies by license type, position held, and agency, certain states will require MU2 control persons to complete a CBC through NMLS as a condition of the license renewal application.
    Generally, to obtain a CBC through the NMLS, the control person must complete two steps: 1) authorizing a CBC, and then 2) scheduling and completing a fingerprint appointment with Fieldprint through NMLS. Please note that Fieldprint is the only NMLS approved vendor for this process. Even if the control person has electronic scanned fingerprints from another vendor, they still must schedule an appointment with Fieldprint through NMLS to have their fingerprints re-scanned with a Fieldprint agent as part of this process. If a company holds a license that will require CBC through the NMLS as part of renewal, the appointments for taking control person fingerprints can be scheduled now.
  3. Make sure that any computer used for NMLS filings is up to date. NMLS has implemented an access restriction for outdated internet browsers. Users must be sure that their internet browser is updated prior to attempting to access the NMLS site for renewals. This is particularly important if individual control persons will be attesting remotely.

Taking care of the above items now may reduce the likelihood of unpleasant surprises and ensure that your company is able to continue to conduct business after the New Year.