On behalf of the state regulatory agencies using NMLS, the State Regulatory Registry LLC is seeking comments from the public on the proposed background check policies and functionality in NMLS. The deadline for comments is October 14, 2009.
Comments are sought on background check policies and processes as well as the following specific areas:
1. Flagging credit history data for specific items in order to decrease the processing time required for regulators to review credit report data. SRR is concerned that applications for licensure or renewal could be significantly delayed if all state regulators must manually review each credit history report for each state licensed MLO. State regulators are proposing to flag for manual review only those credit histories that contain certain incidences.
2. SRR specifically invites comments to identify a score they believe to be an appropriate threshold to trigger manual review. Credit scores can be a means to provide a general assessment of overall credit worthiness. Given the mortgage industry's experience in using credit scores, SRR invites feedback concerning the value of a credit score as only one element of the flag process that can allow a regulator to forego a manual review and expedite processing.
Comments are requested to be limited to the content of this document as it relates to background checks and NMLS.SRR's Mortgage Licensing Policy Committee (MLPC) will review all comments and publish a final document outlining NMLS Background Check Processing.
Comments can be submitted by email to: comments@stateregulatoryregistry.org.
Comments may also be submitted in physical form to:
Conference of State Bank Supervisors
Attn: Tim Doyle Background Check Public Comments
1155 Connecticut Avenue,
NW Fifth Floor
Washington, DC 20036-4306
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