If you have a current Florida mortgage lender, correspondent lender, mortgage broker business, or mortgage broker license, you should have received a letter from the Florida Office of Financial Regulation letting you know that you must start using their new online system called REAL. The letter gave you an authorization code to create an account for you to input your license information. If you did not receive your authorization code letter, you must call the Office of Financial Regulation.
From now on, all license applications, scheduling of the broker or principal representative exam, license renewals, filing of quarterly reports and all other functions associated with your license must be done through their online system.
The new system removes all paper filings, including a paper license. If an investor requires proof that you have a valid Florida license, you will have to print out your information from the database.
Monday, April 14, 2008
Monday, April 7, 2008
Notification of Changes
I hope you are aware that when you change addresses or get a new qualifying person (one whose experience and maybe residency permits the company to get and maintain a license), add or close a branch, or change contact persons for licensing, audits, complaints, etc., you are supposed to notify the banking department. Each state has its own requirements of how much advance notice it requires, but generally the timeframe is thirty days prior written notice. You may be required to send a letter on company letterhead or complete a form that is on the banking department website. Check your state’s regulations so that you are in compliance.
The most radical change is change of control. Most states treat this situation as a new license application, when you notify them. There is usually an extensive form to complete and all new owners, officers, and directors must complete personal biographies, financial statements, and undergo fingerprinting, if it was required with the initial application for the company license. The new owners are not permitted to solicit new business until they receive approval from the banking department of the change in control. The new company owners can only finish out the existing pipeline. Because there is extensive background checking by the regulatory agency, the timeframe for approval is similar to that of a new license application. And approval is not just a rubber stamp. If the new owners would not have been licensed on their own, they will not be approved by the banking department just because they are part of a going concern.
The most radical change is change of control. Most states treat this situation as a new license application, when you notify them. There is usually an extensive form to complete and all new owners, officers, and directors must complete personal biographies, financial statements, and undergo fingerprinting, if it was required with the initial application for the company license. The new owners are not permitted to solicit new business until they receive approval from the banking department of the change in control. The new company owners can only finish out the existing pipeline. Because there is extensive background checking by the regulatory agency, the timeframe for approval is similar to that of a new license application. And approval is not just a rubber stamp. If the new owners would not have been licensed on their own, they will not be approved by the banking department just because they are part of a going concern.
Tuesday, April 1, 2008
Waiting until the last minute
I have just spent the last 2 days at my computer trying to get a client’s license renewal application through the state's online system. The amount of time I have wasted is staggering.
Most states have now moved their annual reports and license renewals to online systems. I’m sure it is much more convenient for the banking departments but for the person who must input the information, it is very time-consuming. Most of those states have stopped using paper forms so you don't even have a choice.
The person who designed the system has, in many cases, made it impossible to see all of the information that is being requested if all of the information on the current screen is not inputted. The system just does not let that page get submitted if you leave any blanks. So, unless you are doing the input for your own company, your assistant, compliance department, or lawyer must go screen by screen to learn what information will be needed and must input every field, leaving no blanks, or you can’t get any further. This means that, if another person than you is doing the input, they are requesting information in bits and pieces. I’m sure you love getting interrupted 10 times a day to answer questions regarding the same subject.
Worst of all is if you wait until the last minute to submit an annual report or file a license renewal. Today is the last day for the Georgia license renewal. Every screen that I tried to input showed an internal error with the server. All day yesterday, until 10:00 p.m., I tried to just start the procedure and was unable to do so. The system was overwhelmed with last-minute filers. My client had not notified me until yesterday that he intended to renew the license so I was not going to start the procedure if the client had no intention of renewing. I did start reminding him a month ago about this deadline. And, of course, I did not have all the information I needed to renew the license all at once. After taking a half-hour to get through the first set of questions, I needed to get more information and the people I needed to get me the information were unavailable. I'm sure this happens in your company as well.
So, my advice to all is not to wait until the last minute to file anything online. The systems inevitably crash from the overload and it will take you 10 times as long as it should to get the project done.
Most states have now moved their annual reports and license renewals to online systems. I’m sure it is much more convenient for the banking departments but for the person who must input the information, it is very time-consuming. Most of those states have stopped using paper forms so you don't even have a choice.
The person who designed the system has, in many cases, made it impossible to see all of the information that is being requested if all of the information on the current screen is not inputted. The system just does not let that page get submitted if you leave any blanks. So, unless you are doing the input for your own company, your assistant, compliance department, or lawyer must go screen by screen to learn what information will be needed and must input every field, leaving no blanks, or you can’t get any further. This means that, if another person than you is doing the input, they are requesting information in bits and pieces. I’m sure you love getting interrupted 10 times a day to answer questions regarding the same subject.
Worst of all is if you wait until the last minute to submit an annual report or file a license renewal. Today is the last day for the Georgia license renewal. Every screen that I tried to input showed an internal error with the server. All day yesterday, until 10:00 p.m., I tried to just start the procedure and was unable to do so. The system was overwhelmed with last-minute filers. My client had not notified me until yesterday that he intended to renew the license so I was not going to start the procedure if the client had no intention of renewing. I did start reminding him a month ago about this deadline. And, of course, I did not have all the information I needed to renew the license all at once. After taking a half-hour to get through the first set of questions, I needed to get more information and the people I needed to get me the information were unavailable. I'm sure this happens in your company as well.
So, my advice to all is not to wait until the last minute to file anything online. The systems inevitably crash from the overload and it will take you 10 times as long as it should to get the project done.
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