Since I always knew that I had to do the report, and since we were organized in such a way to make preparation less painful, I got used to preparing the report each year during the first week of January when the forms became available on the Texas state mortgage lending website. I was very surprised, therefore, to see that this year no report was posted. I waited a couple of weeks to see if they were just behind in setting up the report, since I knew that the state regulators had their hands full with getting the state licensees converted to the NMLS system, but after a couple of weeks when the website still showed no links for our broker report, I called the state. "You don't have to do one this year," the young man working in broker compliance cheerfully informed me, "Isn't that great!"
Actually, it was kind of great. Of course I knew that NMLS would have its own reporting system, and that system is now in place. Instead of our former state reports that we as designated brokers produced, we will now be completing the Mortgage Call Reports. Mortgage Call Reports are to be prepared quarterly by each loan originator. The first report is available today and it is due by May 15. Some states are allowing a longer period of completion for the first report but I believe that Texas is requiring that everyone complete the form by May 15. Failure to complete a report and upload it in a timely manner is cause for license suspension. (The same was true in the case of our Texas annual reports.)
In addition to having the reports available, NMLS offers sample PDF files on line that we can look at to the see the type of information required. For a true broker, as I am, the report is not really all that bad. As in the case of the old state reports, we have to complete the dollar amount and number of each type of loan originated (conventional, FHA, VA or Rural). Reverse mortgages are in a separate listing. Home purchases and refinances are broken out separately to be listed by number of such loans originated and dollar amount of the loans.
One noticable difference between the state report and the NMLS call report is that the call report requires that we state the total dollar amount of the broker fees and lender fees on our transactions for the quarter. Listing our compensation seems to be to be an odd requirement for a federal report and it is going to require that we have our HUD settlement statements at hand while doing our computations. The report also asks us to list the number of applications in process at the beginning of the quarter, the number of approved applications withdrawn by applicants and the number of denied applications. This is a big departure from our state report which required information on closed loans only.
The facts I have presented above apply to mortgage brokers only. Bankers and companies which sell directly to Fannie Mae and Freddie Mac have to complete a more difficult detailed report.
Fortunately, (I guess) the first quarter has been slow, so compiling all of the information for the report should not be that difficult. And to assist us in preparation of our Call Report NMLS is scheduling workshops to teach us how to complete the forms. Information on the workshops has been posted to the NMLS website:
- Policies regarding who needs to submit the Call Report and when
- Directions on which portions of the Call Report need to be completed by which companies.
- Resources for how to complete the report, including field definitions.
- Overview of the options for uploading the Call Report data to NMLS
- Understanding how the data is used by regulators.
- Thursday, May 5, 2011 from 1:30 - 3:00 pm ET
- Tuesday, May 10, 2011 from 1:30 - 3:00 pm ET