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#2254912 - 06/07/21 01:39 PM Credit Report for NMLS Renewals
It's not easy Offline
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Joined: May 2009
Posts: 120
Is ordering and reviewing a credit report required when renewing NMLS? If so, can you please point me in the right direction? I thought it was required as the LO's had to maintain good credit. Thanks!

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Loan Originator Compensation Rule
#2254916 - 06/07/21 02:10 PM Re: Credit Report for NMLS Renewals It's not easy
rlcarey Offline
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Joined: Jul 2001
Posts: 76,786
Galveston, TX
For State licensing I believe it is required, but I am not aware of it for registration renewal of a MLO at a financial institution.
The opinions expressed here should not be construed to be those of my employer:

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#2254917 - 06/07/21 02:17 PM Re: Credit Report for NMLS Renewals It's not easy
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,549
Look at comment 3 to 1026.36(f)(3)(ii):

"3. Subsequent determinations. The loan originator organization must make the required determinations for an individual before the individual acts as a loan originator. Subsequent reviews and assessments are required only if the loan originator organization knows of reliable information indicating that the individual loan originator likely no longer meets the required standards in § 1026.36(f)(3). For example, if the loan originator organization has knowledge of criminal conduct of its individual loan originator through a newspaper article, a previously obtained criminal background report, or the NMLSR, the loan originator organization must determine whether any resulting conviction, or any other information, causes the individual to fail to meet the standards in § 1026.36(f)(3)(ii), regardless of when the loan originator was hired or previously screened."
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.

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#2254920 - 06/07/21 02:52 PM Re: Credit Report for NMLS Renewals It's not easy
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,235
Cape Cod
Also take a look at comment 36(f)(3)(iii), which refers to a bank's "written procedures" for making the determinations. Your bank should have such procedures. They should probably include procedures concerning the circumstances that would trigger the need for a "subsequent review and assessment" of an MLO's financial responsibility, character and general fitness for the responsibilities and duties of an MLO.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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