Welcome to the new world of lending. As the industry is trying to catch it’s breath from the December 31st, 2010 deadline for registration & testing, the next bureaucratic landmine is already waiting to further confuse & occupy the licensed originator community. The NMLS has created the NMLS Call Report, which requires companies to produce production data from any mortgage activity by any mortgage licensee working for the company, every 90 days. Additional financial reporting requirements are incumbent upon larger lending institutions. Keep in mind, federal and state chartered banks have no compliance obligation to NMLS.
Take a look at a few of the field IDs that NMLS asks for in the report. Every lead and application generated by any licensed originator must be measured, every 90 days. Inquiries amongst my colleagues suggests that few are aware of the NMLS Call Report and fewer still have systems in place that are capable of tracking and reporting all of the information required.
How did NMLS create this form?
With an archaic website and virtually no effective social communication tools in place, there isn’t a lot of “why behind the what” explanation coming from the NMLS. My best guess is that the NMLS took the data fields from individual state reports and merged them into one master report. No regard to workflow differences in various parts of the country. No regard to software and hardware enhancements needed to accurately track the data. With each additional requirement the expense for compliance grows, indirectly increasing the cost consumers will pay for home financing services.
With more pressing deadlines looming last year, few added their two cents during the comment gathering process. I’ve heard that less than 100 comments were received during the commenting period. NAMB commented on the issue in May, 2010. Now that the deadline for the first report is less than three months away, expect others to begin voicing concerns. For what it’s worth, the NAMB tactic of challenging the authority of NMLS to even mandate this requirement seems worth pursuing.
My friend Bill Kidwell over at IMMAAG, summed up the NMLS Call Report best, “One more example of an OK idea (gathering data) being implemented with woefully inadequate thought.”
January 17, 2011: Texas Assn. of Mortgage Brokers have posted about NMLS Call Reports.
February 8, 2011: Lenders Compliance Group has posted about NMLS Call Reports.
February 11, 2011: FDIC link for Call Report Data Call/TFR Information
March 7, 2011: Mortgage License Solutions Blog, Do You Still Need to File an Annual Report?
March 24, 2011: Scotsman Guide, Answering the Call of Duty
April 27, 2011: Calyx Software, NMLS Call Reports in Point