WBK Industry - Federal Regulatory Developments

Comments Requested on Proposed Changes to the Mortgage Call Report

As part of efforts to modernize the NMLS, both the State Regulatory Registry LLC (SRR) and the regulators of the Mortgage Call Report Working Group intend to improve reporting functionality, and the SRR, on behalf of the state regulatory agencies using the NMLS, have asked for public comment regarding certain proposed changes. These efforts are part of the furtherance of one of the goals of the NMLS Mortgage Call Report (MCR), which is, over time, to include all information required by state regulators in the Report so as to eliminate the need for submissions and tracking of requirements outside of the NMLS.  The features of the proposed revised MCR include:

  • Inclusion of a business activities approach whereby companies will only be required to complete the sections of the MCR related to their operations.  For instance, if a company is only licensed to engage in activities as a servicer, it would not need to complete MCR sections that pertain to lending.  Comments are requested in connection with the proposed dynamic Report form which will focus sections to complete based upon the business activities indicated by the company on their company form.
  • Update of MCR definitions and instructions to better define them in, and exclude commercial and non-mortgage activity from, the Residential Mortgage Lending Activity sections.  In addition to updating fields to include changes in accounting standards, another goal was to unify the standard and expanded financial condition forms into one form for all filers.  Comments are requested in connection with proposed changes to current definitions and instructions, as well as proposed changes to the financial condition report.
  • Proposed addition of a Supplemental State-Specific Form where states would ask Report filers to provide information that is specific to a state and that would satisfy that state’s requirements, with the goal of eliminating reports that are currently required to be submitted outside the NMLS.  Comments are requested in connection with the proposed schedules to be used in this form to request the state-specific information.

The comment submission deadline is April 13, 2018.