Wow....I thought I had a grasp on this but after reading this string I am completely confused
On current employees, if they have been run through NMLS system no need to go back and rescreen.
For employees who are not NMLS registered but under the new rule fall under the definition of a MLO we do have to perform credit and criminal history checks.
For new employees qualifying as MLO, after Jan 2014, will run through the criminal and credit history check process.
If the employee needs a NMLS then the check is done annually.
If the employee does not need a NMLS, then the check is a one time only process.