I have a lender that had to attest twice to his annual renewal and was not abel to get hi NMLS recod renewed till the 17th of January. He only took 3 applications in the period where his renewal finally went through,would that be an issue? Can this qualify under the De Minimis Exception of 5?

Appreciate guidance on this.

Ah - not on your life. De mininmus covers the last 12 months, not the first 17 days of the year. You have a real problem here and a serious weakness in your program.

Thank you for your response.