November 2008 Mortgage Licensing Update

With the S.A.F.E. Mortgage Licensing Act passing onmortgage loan originator as an employee or
June 30, 2008, there are a lot of changes expected toindependent contractor of a licensed Delaware
happen soon in mortgage licensing. At this time, onlyMortgage Broker or Lender. The legislation requires a
about one third of the states are in compliance withmortgage loan originator to apply to the Office of the
the federal law, and since most states are not going toState Bank Commissioner for a mortgage loan
want to hand over their licensing to the federaloriginator license, establishes initial and continuing
government, you can expect for many new laws toeducation requirements for licensees, and authorizes
be passed in the near future. Here are some recentthe Commissioner to adopt regulations to facilitate
changes to be prepared for.participation in the Nationwide Mortgage Licensing
Michigan Loan Originator LicensingSystem. The bill requires that loan originator licensees
As of January 1, 2009, Loan Originator must behave at least 18 hours of education courses within the
licensed to originate mortgage loans. Prior to that date,five years prior to licensure, or within one year
Michigan only required Loan Originators to be w-2following licensure. Applicants may work as mortgage
employees of a licensed mortgage company. Theloan originators upon initial employment on a temporary
new law requires the Loan Originator to have eitherbasis until the person is either licensed or the application
4.5 years of experience originating loans in the last 5is denied. Applicants must submit a $250 investigation
years or take a 24 hour live education course. Oncefee and a $250 annual license fee.
either experience or education is met, then the LoanRhode Island Loan Originator Licensing
Originator is required to take a Michigan LoanLicensing requirements for Rhode Island Loan
Originator Test. The test just became available onOriginators are now posted on the Nationwide
October 21, 2008. Loan Originators must then completeMortgage Licensing System (NMLS) website. A Loan
fingerprint cards or live scan fingerprinting and go on toOriginator license must be obtained by January 1, 2009
the Nationwide Mortgage Licensing System (NMLS)in order to continue originating in the state of Rhode
and submit a Loan Originator (MU4) application andIsland. The application requires fingerprint cards, 20
then mail all of the previous documentation directly tohours of pre-licensure education, a personal financial
the state. Everything is currently due to the state by 12statement showing a positive net worth, a copy of a
4/08 to guarantee that a Loan Originator License isvalid photo ID (for example, driver's license), and the
issued by 1/1/09, however, details on the fingerprintingsubmission of a Loan Origiantor Application (MU4) on
process has not been released yet, so I expect themthe NMLS. Applications are due by 11/1/08 in order for
to give Loan Originators an extension. Keep in mind,applications to be approved by 1/1/09. Also, starting in
that it is just my opinion, so don't delay in following thethe 2nd quarter of 2009, Rhode Island expects to
state requirements and meeting the deadlines.have a testing requirement.
Delaware Loan Originator LicensingNationwide Mortgage Licensing System
Delaware House Bill 508 becomes effective onNew states transitioning onto the NMLS on November
January 1, 2009, but mortgage loan originators will not1, 2008 are: Arkansas, Indiana, Pennsylvania, and
be required to obtain a license until the State BankWyoming. Michigina began transitioning on October 1,
Commissioner adopts regulations implementing the2008. All of these states require transitions to be
new licensing laws. At this time, there is nothing on thecompleted by December 31, 2008. Also, most states
states website implementing the Delaware Loanalready on the NMLS will be using the NMLS for
Originator Licensing requirement, so it will probably notrenewals. There are currently 19 states on the NMLS
be requred until later in 2009. HB 508 defines aand all states are expected to be on by 2010.