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Discover the latest updates on collaborative licensing and the NMLS Key Individual Wizard at the North American Collection Agency Regulatory Association Annual Conference. Learn about the benefits, outcomes, and improvements to licensing and vetting processes. Don't miss this intuitive tool for licensees!
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September 16, 2019 NMLS Update North American Collection Agency Regulatory Association Annual Conference & Training September 16, 2018
NMLS in 2019 • Collaborative licensing • NMLS Key Individual Wizard • State Examination System • NMLS License Wizard
Collaborative Licensing CORE Information& Standards Agency-Specific Information Phase 1 Phase 2
KIWI WORKING GROUP PAIN POINTS ADDRESSING A LONG AND PERSISTENT PROBLEM RESPONDING TO ONE AGENCY CREATES QUESTIONS FOR ANOTHER EXAMINE EXISTING PROCESSES Evaluating the ‘why’ somebody has to be vetted versus disclosed Frustrations regarding consistency and transparency Frequent complaint between regulators and industry
KIWI WORKING GROUP OUTCOMES INTUITIVE TOOL TO ASSIST LICENSEES INTENT OF ‘CONTROL PERSON’ COMMON DEFINITIONS + INTERPRETATIONS Emphasis on functional responsibilities + risk Less emphasis on job titles Both industry + regulators agree Consistent standard regardless of business activity Identify individuals included as part of an application Distinguish disclosed vs. vetted individuals
CONSISTENCY AND RELIABILITY All individuals associated with applicant Individuals disclosed on NMLS Company Licensure Form Applicant identifies key individuals based on a standardized questionnaire approved by state regulators Individuals requiring vetting by state agency
KEY INDIVIDUALS RISK+ FUNCTIONALAREA INDUSTRY SPECIFIC ROLES KEYINDIVIDUALS MANAGEMENT STRUCTURE OWNERSHIP STRUCTURE
KEY INDIVIDUALS BY RISK / FUNCTIONAL AREA FINANCE OPERATIONS INFORMATION SECURITY COMPLIANCE
DISCLOSURE REQUIREMENTS 100% ownership for both direct and indirect owners All owners with more than 10% interest in the applicant Disclosure requirement percentages calculated automatically New ownership disclosure rules: • trust • investment funds • minority interest
KIWI KEY INDIVIDUALS DISPLAYED IN A FINAL REPORT WHO NEEDS TO BE DISCLOSED VERSUS VETTED Risk/Functional area of responsibility Ownership disclosure rules Agency license setting BASED ON:
KIWI – Applicant Information Excel Corporation
What will SES do? • SES will do for examinations what NMLS did for licensing: • Increase uniformity • Decrease compliance friction • Expand information sharing
Built by examiners from 14 states WA ME MT ND MN VT OR NH ID WI NY MA SD RI WY MI CT PA NJ IA NE NV OH DE IN IL UT MD CO WV CA VA DC KS MO KY NC TN AZ OK AR SC NM GA AL MS TX LA FL
Pilot and nationwide launch Handful of exams conducted by agencies in SES stakeholder group Pilot Oct. – Dec. 2019 Gradual implementation beginning with states that accepted the SES scholarship (28 as of now) Nationwide Launch Early 2020
What will SES do in the (near) future? • Investigations • Consumer complaint processing • Enforcement actions
September 16, 2019 License Wizard Bill YoungVice PresidentConference of State Bank Supervisors (CSBS)
License Wizard Goals • Provide an easy-to-use and highly educational tool for license applicants • Help applicants find the appropriate license and New Application Checklist • Reduce calls to regulators and the call center • Reduce instances of licensee getting the wrong license (data fixes, refunds, etc.) • Enrich the NMLS data set
Has anyone tested out the license wizard? What did you think? Have you heard any feedback from others? Do you think this will resolve confusion around selecting the correct license type?
Timeline ? Jan 2019