COVID-19

COVID-19: Education, Testing & Reporting Deadline Changes Due to COVID-19

COVID-19The coronavirus pandemic (COVID-19) has disrupted many daily professional and personal activities across the nation. For mortgage brokers who are facing deadlines for their license applications and renewals, these circumstances can create additional anxiety.

While the current pandemic is causing many things to change from day-to-day, the following information provides an update to mortgage brokers who are attempting to meet licensing and educational requirements amidst the pandemic.

Licensure & Renewals

Prior to state licensure, applicants must first pass the National Test, administered by Prometric through NMLS or FINRA. In adopting the guidelines administered by the Centers for Disease Control and Prevention to minimize the spread of COVID-19, Prometric closed its test centers on March 18. They are currently slated to reopen on May 1, 2020.

While Prometric and NMLS are considering alternative methods of testing, mechanisms for this are not currently in place. NMLS has indicated that any updates regarding potential alternate exam delivery methods will be posted on their Resource Center.

For candidates with existing appointments, NMLS has indicated that these test-takers will receive an email notification once their appointment has been canceled, and they will be able to reschedule the test date. Future exam dates will not be available until May 1, at the earliest. In these instances of rescheduling exams, the normal rescheduling fees will not be applied due to COVID-19.

Any candidate with a test enrollment window that was scheduled to end in March, April, May, or June will automatically receive a 180-day extension. If the test centers continue to be closed beyond May 1, the enrollment window may be extended beyond the current 180-day extension.

Most state licensing agencies have also issued extensions for the current licensure renewals and applications in order to provide applicants with sufficient time to complete the national exam first. Applicants should work with their state licensing agency to determine their processes, requirements, and timelines during COVID-19. Their information frequently changes daily, so a proactive approach to determining the requirements is your best bet for ensuring that you meet any applicable requirements.

Continuing Education

Meeting the continuing education requirements for mortgage brokers may pose an additional challenge during the coronavirus outbreak as most (if not all) in-person classes have been canceled across the country for the time being. Fortunately, many continuing education requirements for mortgage brokers can be completed online with licensing maintenance service providers.

However, many states have also made changes to their state continuing education requirements simply due to the uncertainty that COVID-19 is causing and its upheaval to daily life. Any mortgage broker who is working through their continuing education requirements should work with their state licensing agency to determine if changes have been made to state policies and to identify acceptable online courses, if available, prior to enrolling.

Reporting

Financial institutions of all types – including mortgage brokers – have reporting requirements that may be challenging to meet during the pandemic. In light of this, the Consumer Financial Protection Bureau (CFPB) has announced its decision to postpone certain data collections within the financial services industry to allow companies to focus on maintaining operations and assisting consumers.

Specific to mortgage brokers, CFPB’s announcement has lifted the requirement for quarterly information that would normally be required under the Home Mortgage Disclosure Act (HMDA) and Regulation C. However, they have also advised that data collection and recording of this information should continue as it normally would to ensure that this data will be available when making the required annual submission.

In addition to this reporting change, the NMLS policy committee has announced the extension of certain deadlines for reports that would normally have been due during this time. The following is an overview of the changes:

  • Mortgage Services Businesses Call Report, Q4 2019: Initial due date of March 31, 2020, revised to April 30, 2020.
  • Mortgage Call Report, Q1 2020: Initial due date of May 15, 2020, revised to June 14, 2020.
  • Mortgage Services Businesses Call Report, Q1 2020: Initial due date of May 15, 2020, revised to June 14, 2020.

The Mortgage Standard Financial Condition and Financial Statements reporting requirements have been altered as well. While both are normally due within 90 days from the end of a company’s fiscal year, they are now required within 120 days from the end of the fiscal year.

Despite this overview of changes, it’s important to keep in mind that the COVID-19 situation is changing rapidly, and responses may vary from state to state. It’s crucial to stay on top of the changing requirements federally, as well your own state.