Mandatory Transition to NMLS August 1, 2017 through September 30, 2017 - Financial Regulation
TO: All Licensed Check Cashing Services, Debt Management Services, Collection Agencies, Consumer Lenders, Installment Lenders, Sales Finance Companies, and Credit Services Businesses
FROM: Maryland Commissioner of Financial Regulation
RE: Official Notice of Adoption and Transition to NMLS
DATE: June 30, 2017
MANDATORY TRANSITION TO NMLS AUGUST 1, 2017 THROUGH SEPTEMBER 30, 2017
Pursuant to the enactment of House Bill (HB) 182 (253 Md. Laws 2017), passed earlier this year by Maryland’s General Assembly and signed into law by Governor Larry Hogan, the Commissioner of Financial Regulation (“Commissioner”) is proud to announce that starting August 1, 2017, the Commissioner will begin using the Nationwide Multistate Licensing System & Registry (“NMLS”) to manage all licensing activity for Check Cashing Services, Debt Management Services, Collection Agencies, Consumer Lenders, Installment Lenders, Sales Finance Companies, and Credit Services Businesses. Through NMLS, you will be able to apply for, amend, and renew your license authority conveniently and safely online, as well as handle other licensing requests (such as change of address or change in control). The purpose of this letter is to provide you with the official 30-day notice of adoption and transition to NMLS required under HB 182, and to provide you with important information to help you prepare for your required transition to NMLS.
NMLS is a secure web-based system created by state regulators to provide efficiencies in the processing of state licenses and to improve supervision of state-regulated financial industries. Through NMLS, business entities maintain a single record which they use to apply for, maintain, renew, and surrender licenses in one or more states. NMLS also contains functionality for the submission of financial statements, credit reports, electronic bonds, and criminal background checks if required for your license. More information about NMLS can be found on the NMLS Resource Center.
Managing Your License on NMLS
Each licensed Check Cashing Service, Debt Management Service, Collection Agency, Consumer Lender, Installment Lender, Sales Finance Company, and Credit Services Business is required by law to create and maintain a record in NMLS, both for the business entity itself, and for each branch required to hold a license. Once the business entity and branch forms have been completed, they may be submitted electronically through NMLS to the Commissioner starting on August 1, 2017.
NMLS will be available for you to create and begin completing your licensing record beginning August 1, 2017. A copy of the Commissioner’s license Transition Checklist for each license type will be available soon on the NMLS Resource Center.
How to Access NMLS Beginning August 1
NOTE: If you already have a record in NMLS, there is no need for you to complete this step.
In order to gain access to NMLS for the first time, you must complete a Company Account Request Form and identify a Primary Account Administrator and a Secondary Account Administrator. This form can be submitted electronically through the NMLS website in the Getting Started section. This form needs to be submitted only once, regardless of the number of NMLS participating states in which you are licensed.
Within three days of completing and submitting the Company Account Request Form, the Primary Account Administrator will receive NMLS login information. The Primary Account Administrator for your company will have full rights to access the system, submit information to the Commissioner and other participating state regulators, and set up other business entity users in the system. Instructions and tutorials on how to access and use the system are also available on the NMLS Resource Center.
Forms to Complete
Once you are able to access NMLS, you will be required by law to submit the following through NMLS to the Commissioner by September 30, 2017 (In accordance with HB 182, all licensees MUST complete the transition by this date):
- Company Application
- Submitted by Licensed Companies
- For more information, see the Submitting a Company (MU1) Form Quick Guide.
- Biographical Statement and Consent Form
- Submitted by Licensed Companies for each Control Person (i.e., executive officer, qualified individual or branch manager)
- For more information, see the Submitting an Individual (MU2) Form Quick Guide.
- Branch Application
- Submitted by Licensed Companies for each Licensed Branch
- For more information, see the Submitting a Branch (MU3) Form Quick Guide.
You may begin completing these forms prior to August 1, 2017, but will not be able to submit them to the Agency until that date. See the Company (MU1) Form Filing Instructions if you are completing the Company (MU1) Form for the first time.
NOTE: If you have submitted these forms to another state, then you do not need to re-enter your company or branch records into NMLS. You will only need to identify the appropriate license type in Maryland and complete a few state-specific fields.
License Extension Fees
In accordance with HB 182, for each license you hold that will transition to NMLS, the term of that license shall be extended to December 31 of the year in which the license would otherwise have expired, and during the transition period (August 1, 2017-September 30, 2017), you will be required to pay a license extension fee. The fee is based on the annual license fee, and will be prorated to the number of days between the date the license would otherwise have expired and December 31 of the same year. You will receive a bill from the Commissioner for this fee during the transition period.
The Commissioner will participate in a NMLS Training Webinar conducted by the State Regulatory Registry LLC for Maryland Licensees on Tuesday, August, 8th, 2017 at 1:00 PM ET. If you are not a current NMLS user, the Commissioner strongly recommends that you attend this training.
This training is intended to help you transition your existing license(s) on to NMLS. The training will include an overview of the resources available, licensing requirements checklists that should be reviewed, and a demonstration of tasks that must be completed in NMLS.
Go to the CSBS Learning Management System to register for the training. There is no fee to participate. When registering, enter the subscription code: MDTRANSITION20170801. This session will be recorded.
NOTE: Space is limited to 500 attendees and will be granted on a first come first served basis. If you are unable to attend the live training, you will be able to access the training’s recording.
The NMLS Resource Center provides step-by-step instructions on how to access the system, guides on how to complete the forms, each state’s Transition Checklist, tutorials, current and future participating agencies, system alerts, system processing fees, and general background information. Training opportunities are also available in the News & Events section and from the NMLS home page.
If you have any questions, feel free to contact the Non-Depository Licensing Unit by phone at 410-230-6155 or by e-mail at FinReg.Licensing@maryland.gov.
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