On Monday, state agency IT staff met to discuss the technical details of using NMLS.
The Tech Track was attended by about 20 state IT professionals. The agenda was designed to be highly interactive to assist CSBS IT staff in understanding how CSBS can assist state IT organizations in addressing evolving IT and security concerns, specifically regarding NMLS. The agenda included:
- The NMLS roadmap, presented by Mike Belak.
- Current and planned enhancements to NMLS security controls, presented by Mark Rippe.
- The State Regulatory Registry’s (SRR) implementation of SalesForce.com for the NMLS Call Center, as well as tracking and responding to requests from state IT departments, presented by Kathy Hunter.
- Peter Wallace facilitated a discussion sharing successes and challenges experiences by state IT organizations regarding similar IT needs, as well as a roundtable discussion of specific items that are of greatest interest to state IT departments and solutions CSBS might provide.
CSBS staff collected a lot of feedback from the states, which will all be documented in Clarizen as issues, where they can be prioritized and tracked. Where it is not feasible to list all feedback here, some common themes were:
- State IT professionals expressed their willingness and desire to be engaged early in any activities that do have or may have a technology element or impact.
- State IT professionals provided feedback regarding improvements in the NMLS software development life cycle process that would enable new functions to be implemented in a more agile fashion.
- State IT professionals provide specific feedback to the current NMLS data download process and recommendation for improvement.
CSBS technology staff continue to be appreciative of the feedback from the state IT professionals at the NMLS conference and ongoing throughout the year. There was general consensus among the group that the nature and scope of the discussions warranted expansion of the Tech Track at the next conference to two days.
Yesterday there was a fascinating breakout session titled “Licensing on NMLS: A Focus on Debt Collectors.”
Elizabeth Benotti, Chief Director of Consumer Finance and Money Service Business of the Massachusetts Division of Banking; and Chris Ludwig, Consumer Licensing Division Supervisor of the North Dakota Department of Financial Institutions, spoke on the panel moderated by Mary Pfaff of CSBS.
Here’s a photo of the panel in action.
Cindy Begin, Chief Risk Officer of the Massachusetts Division of Banks and President of the American Association of Residential Mortgage Regulators (AARMR), discusses AARMR’s role in state mortgage supervision.
Day Two of the 6th Annual NMLS Conference is about to begin!
This morning we kick off with the Regulator Meet & Greet Breakfast from 8:30 to 10:00 am. This breakfast gives members of industry a chance to sit down and meet face-to-face with their state regulators.
Following the breakfast, the General Session begins with remarks by Holly Petraeus, Assistant Director of the Office of Servicemember Affairs at the Consumer Financial Protection Bureau (CFPB).
Next up will be a dialogue on consumer complaints from 10:45 am to 12:15 pm. This panel will feature Tom Candon, Deputy Commissioner of Banking & Securities of the Vermont Department of Financial Regulation; Scott Pluta, Assistant Director of the CFPB; and Larry Hattix, Ombudsman of the Office of the Comptroller of the Currency (OCC). The panel will be moderated by Chuck Cross of CSBS.
Bob Entringer, Commissioner of the North Dakota Department of Financial Institutions and Chairman of the State Regulatory Registry (SRR) Board of Managers, spoke on the latest updates and enhancements to NMLS.
Drew Breakspear, Commissioner of the Florida Office of Financial Regulation, provides a status report on the state of Florida’s economy and discusses his supervisory priorities.
Kevin Crocker, Attorney with Barron and Newburger, P.C., provided his insight on the impact NMLS has had upon the financial services industry.
Question: Your clients are non-mortgage, non-depository financial services providers, such as debt buyers. Can you tell me a bit about the regulatory environment for these providers?
There are varying, inconsistent regulatory schemes across the country. We are hopeful that the use of the NMLS process will simplify licensing and reduce the costs of compliance for industry members who are subject to licensure.
Question: What key issues do you anticipate the industry will be dealing with in the coming few years?
The rules that ultimately are adopted in the wake of the CFPB’s advance notice of proposed rulemaking are likely to be a game-changer. The federal government has never implemented rules pertaining to the Fair Debt Collection Practices Act (FDCPA). The CFPB has an opportunity to deal with many issues that need to be addressed, such as the use of technologies that did not exist when the FDCPA was enacted. We hope that the CFPB will address critical issues for the collection industry, such as voicemail messages and use of email.
Question: How has NMLS had an impact on how your clients do business?
It is too soon to tell in the non-mortgage arena. However, some portions of the process do not appear to be geared to non-mortgage industry clients. It may take some time to get past the round hole/square peg issues that arise because debt buyers and law firms are different businesses than mortgage lenders and servicers.