Written By: Wendy Bernard, Esq., experience includes General Counsel, Director of Regulatory Compliance, Vice President of Quality Control, and Post-Funding Operations for Mortgage Banking/Broker institutions since 1993. She is a member of the bars of the states of Connecticut, New Jersey and New York and is also an Adjunct Professor of Business Law. She is also a Captain in the United States Army Reserve Judge Advocate General Corps (JAG).
Loan officers may not know or care, but if it’s the first quarter of any calendar year, a select group of mortgage professionals are swamped with annual and financial reports that must be submitted by the last day of March or the first day of April, depending on the State or regulator.
The people who typically manage such reporting run the gamut from Sole Proprietors to Operations Officers. In some companies it may be delegated to the Accounting Department in conjunction with Compliance personnel, or either. Regardless of the designated Responsible Party in an organization, the main concern and focus is the same: accurate completion and timely submission of reports.
Missing the deadlines can have significant consequences to the organization both in financial penalties and legislative sanctions. For example, some states may penalize late submissions up to $50.00 per day for every day past the annual report submission date. Others may fine organizations for late submissions and may immediately suspend the entity’s license to conduct business in that state.
Annual and financial reporting compliance for a single jurisdiction is work enough, but if a company is licensed in multiple states, the first quarter can be a daunting undertaking. Approximately thirty-eight states have unique annual reporting requirements and approximately forty-two States have distinctive financial reporting formats.
In addition, if the company is FHA approved, the responsible party must also manage and submit the independent auditor’s report and complete all annual renewal and recertification requirements. Whether reporting concerns the states or FHA, those ninety days from January through April can cause significant anxiety to the person who bears the organization’s reporting compliance burden. Enter the Nationwide Mortgage Licensing System (NMLS).
On March 15, 2010, the NMLS announced that they were seeking public commentary on their proposed NMLS Mortgage Call Report, a reporting system designed to streamline multiple State reporting requirements, purportedly to relieve the state specific compliance burden described above. FHA annual recertification requirements would not be covered under this streamlined report. The Mortgage Call Report may be good news or bad for responsible parties, depending on perspective.
Purpose of the Mortgage Call Report
Read More
