Are You Keeping Your State Regulators Notified About Changes in Your Company?

Have you moved your offices? Has a loan originator been terminated or left your company? Do you have a new branch manager? Has a state or federal agency instituted a cease and desist order or have you entered into a consent agreement?

When any piece of information changes from what is listed in your company MU1, or a branch office MU3 or your loan originators’ MU4 records, you must notify your state banking department. Each state has slightly different requirements about the notification – some states require 30 days’ prior notice, others require 15 days prior notice, other states will allow notice after a situation changes.

Each state has different requirements about the timing but the SAFE Act requires that you update your NMLS records to reflect all changes in your company that pertain to the information that is maintained in the NMLS database. Remember, when you attest to your record (whenever that is required), you are attesting to the fact that all of the information in your company record is still current. Therefore, if you have sponsored a loan originator, and he is no longer working for you, you must change your NMLS record to terminate the sponsorship. If you have moved your office, you must change your MU1. In some cases, you will need to surrender a paper license to get a new one with your new address. Make sure your loan originators update their MU4 records when any information of theirs changes – if they change their residence address or employment address.

It is a good practice to check your NMLS records (all of the company, branch office and loan originator records) on a regular basis so that you remember to make the necessary changes and notify your state regulator. Add this to the list of proactive steps to take so you are always in compliance.