2013 Annual Conference & Training February 26 – March 1 San Antonio, Texas Course Provider Session...

2013 Annual Conference & TrainingFebruary 26 – March 1 San Antonio, Texas

Course Provider Session

Pete Marks, VP, SRRRich Madison, S. Director, SRR

2013 NMLS Annual Conference & Training | San Antonio, Texas

Agenda

• New Education Management System (EMS)• New Business Rules for Education Compliance• 2012 Education Numbers• Education Compliance Examinations• Course Approval Trends• CFPB and New Mortgage Rules• Questions


Staff

• Jessica Ayton – Manager, Mortgage Ed Ops

• Alan Ridenour – Analyst, Mortgage Ed

• Michelle Rosenthal – Sr. Manager, Ed Compliance

• New Hire – Analyst, Mortgage Ed Compliance

• Course Evaluators


Activities

• Course Provider Approval/Renewals• Course Approvals/Renewals• Technical Support – credit banking, systems• State Regulator Support• Policies• Vendor Management• New EMS Build


Education Management System (EMS)

SRR’s existing contract with Pearson for education ends in June 2013. In response: • SRR released an RFP for T&E services Feb 2012• The RFP was released February 3• SRR re-released a modified RFP on May 18• SRR evaluated bids between May 19-July 15 • SRR awarded two contracts on July 24– CyZap (NE-based)– FINRA (MD-based)



Education Management System (CyZap Component)– Hosting, Network, and Database System Management– NMLS-branded Portal• Full Administrative Functionality• Course Provider Functionality

– Provider Approvals, Renewals, Suspensions, and Deactivation• Ability to collect demographic data• SRR ability to set fees, change payment amount,

refunds



– Courses Approvals, Renewals, Suspensions, and Deactivation• Maintain existing course numbering structure• Collect Fee Payment• Send reminder for renewals or other event-based

notifications– Dashboard

• pending, approved renewing, and not renewing providers.– Course Offering Scheduling

• Course Offering Management• Online Course Catalog

– E-Commerce• Implementation of ORCC Pay System• Reporting



- Credit Banking• Submit or Upload (100 students at a time) • Data Validation of NMLS ID and Full Last Name• Interfacing with NMLS (web services)• Editing Course Completion Records/Issues

Resolution



- Reports

- Work Flow Analysis• SRR worked with CyZap Sept - Dec on requirements• Development began in Jan 2013 and will continue through Apr

- Current Status• SRR currently testing provider and course application modules• Initial provider and course data has been imported



Education Compliance Tracking (FINRA Component)- Business Rules Engine • Expanded Education Compliance Tracking Ability

• Federal Requirements• State Specific Compliance Tracking (both PE and CE) (by License Type)

• Ability for State Agencies to Set/Change Education Requirements• Auto tracking/reporting of Late CE

• Administrative Interface• Ability for SRR staff to add or remove a course from a record



- Central Education Data Depository• Import and Host Exiting MLO Education Data from Pearson• Data Validation

- Redesign of Course Completion Record (transcript)

- Reporting• Course Level• State Level• Data Analytics• Custom



Enhanced Provider Services:– Maintain and View Complete Course List– Track All Renewal Dates– System Renewal Reminders– Application Status Tracking– Maintain and Use Credit Card on File– Pay Using ACH– New User Manuals

Basecamp will continue to be used for documents and communications



• View all your courses in one list

• View details of one course record



Key Points for Providers:• Staggered transition plan so providers will use both PUSLE and

new EMS in May and April.• Provider and course data will transfer from Pulse to EMS, but

not course offerings*• Course offerings with start date on or after 5/17 will need to

be entered into new EMS • NMLS will be communicating frequently on the change

*Hint – Only schedule offerings in PULSE through May 17


PULSE

EMS

Submit PROVIDER NEW & RENEWAL

APPLICATION


APPLICATION

Mid May


APPLICATION


APPLICATION

Submit COURSE RENEWAL

APPLICATION Off


APPLICATION Off

Submit NEW COURSE

APPLICATION

Submit NEW COURSE

APPLICATION

Submit NEW COURSE

APPLICATION

Submit NEW COURSE

APPLICATION

May


APPLICATION


APPLICATION

Periodic Scheduled Outages

PULSE to EMS Transition Timeline


PULSE to EMS Transition Timeline

June

Create COURSE OFFERING


June 24

CREDIT BANKINGCREDIT

BANKING

CREDIT BANKINGCREDIT

BANKING

May


Create COURSE OFFERINGEMS

PULSE

Possible Periodic Scheduled Outages


New Course Completion Record (PE)


New Course Completion Record (CE)


New Education Compliance Tracking

- EMS will track state-specific PE/CE Compliance• Courses containing state specific material will be assigned state agency

- Five States have multiple agencies• CA: DRE & DOC• IN: DFI & SOS• SC: BFI & DCA• TX: OCCC & SML• UT: DFI & DRE• OH to be tracked by License Type: OMBA and OMLA

- Course content must be tailored to one agency, even for states with multiple agencies

• NMLS will work with providers on existing courses



New Business Rules that Impact Course Providers

State Agencies will be able to set/change education requirements

• 90 day advance notice to inform providers/industry

• PE compliance is tracked at time of application• If PE requirements change after application, MLO will not have to Complete the new requirements.

• CE compliance will be tracked at time of licensure• If CE requirements change mid-year and MLO has completedCE they will have to meet the new requirement.



New Business Rules that Impact Course Providers

New Uniform CE Policy:

As a condition for license renewal, an MLO is required to complete at least eight (8) hours of CE in the same year in which he/she is placed in an approved license status by a state agency, with the following exception:

• An MLO who has completed his/her pre-licensure education (PE) course requirements in the same year in which the license was approved, is not required to complete CE.

In the event an MLO had a requirement to complete CE and failed to do so, and as a condition for renewal or reinstatement, “Late CE” is required to be completed to satisfy CE for the last year in which the MLO was in a renewable status. “Late CE” courses are those courses which have been specifically approved and configured, so that upon completion, course credit will be retroactively applied to the appropriate previous year.

Additionally and in accordance with the Model State Law (MSL), an MLO who subsequently becomes unlicensed must complete the CE requirements for the last year in which a license was held prior to the issuance of a new or renewed license.



Agencies currently considering making changes to PE/CE:

• HI, NE, TX-SML, TX-OCCC, VT, WA

• WA effective 4/1; others pending

• NMLS will release an “Education Notice” informing course provider at least prior to effective date of change.• Notice will state required number of hours (by subject area)• Course content requirements • State law/statute reference list• Effective date

• On the effective date, existing state-specific courses for that agency will be inactivated, and only new course may be taken to meet the new requirement.


By the Numbers…


Course Application Processing

Steady rate of new courses being submitted:

– 755 new course applications in 2010– 726 new course applications in 2011– 685 new course applications in 2012– Between new and renewal, we’re evaluating over

1200 courses annually


Approved Course Breakdown

20111239 approved courses

389 PE Courses48% of these are PE Comprehensive

850 CE Courses 28% of these are CE Comprehensive

92 Active Late CE Courses

20121151 approved courses

333 PE Courses42% of these are PE Comprehensive

818 CE Courses 28% of these are CE Comprehensive

86 Active Late CE Courses


Credit Banking

20111,478,366 hours banked

42% PE 57 % CE

Delivery Method• Classroom – 24%• CEQ – 10%• OIL – 24%• OSS – 42%

20121,676,261 hours banked

45% PE 55% CE

Delivery Method• Classroom – 23%• CEQ – 6%• OIL – 21%• OSS – 50%


2012 Course Delivery Breakdown

753,981 PE Hours


2012 Course Delivery Breakdown

922,280 CE Hours


Course Renewals

2011– 496 courses renewed– Renewal rate 62%– 80% of course renewal

submissions occur on the last day of the month

2012– 518 courses renewed– Renewal rate 60%– Majority of renewal

applications still come in the last week of the month


Provider Renewals

2011• 152 Approved Course

Providers • 102 Providers Renewed• Renewal Rate of 70%

2012• 165 Approved Course

Providers • 27 Providers Renewed• Renewal Rate of 50%


Course Approval Process

• Good but can be frustrating at time– More consistent feedback– Easier to understand– Entry level or Graduate Level?– NMLS will facilitate conversation between provider and evaluator

• Revisiting OIL approval Process– Provider input on how to deal with 1,2,3 hour OIL PE


Course Approval Process

• 2013: Emphasis on Instructional Design and Quality• We encourage innovation• Forum for Best Practices• Course tips:

– Most common mistake: citations are not current– Note changes on resubmission– No final assessment – No case study


Education Compliance…


Educational Compliance

• Additional resources and focus is being applied– 2 x full-time resources

• Comprehensive strategy – Surveys• Dashboard• Scorecards

– Combined announced visits and “mystery shopping”– Site visits


• Course Surveys: sent to every MLO who completes a course within a week of credit banking.

– Contextual to the four course formats– Measure performance in the areas of instruction,

delivery, administration, and satisfaction– Comments are collected and reviewed monthly




Drive the Dashboard and Scorecards:– Tools being employed to prioritize resources and

more quickly spot potential problems.

– Along with survey comments and audits, enable for better understanding of performance at the macro and micro levels.

– Assist to track effectiveness of staff and provider activities.


Key measures: Goal is to maintain above 4.0 or 90% Negative trending and/or measures in yellow are areas of focus Individual Scorecards are being shared with providers monthly



Key measures: Survey response rate above 20% Scores above 4.0 or 90%



What providers will see:• Individual Monthly Scorecards • Survey Comments• Monthly Summary Report w/Dashboard• Easy-to-Read Compliance Reports• Risk Matrix

Seek to maintain a dialogue with providers• No “gotcha” intent• Site Visits/Desk Visits



• Recent Observations– Some great instruction happening!– Attempting to teach the test (please don’t)– Some instructors need to enhance their skills• Controlling a class• Embrace mobile devices• Focus on time and content requirements



CFPB & New Mortgage Rules…


• CFPB is working on a coordinated implementation plan to assist regulated entities to come into compliance with new mortgage rules.

• Goals:– Maximize awareness– Reduce costs– Increase compliance– Building an internal lessons learned

New Mortgage Rules


• CSBS/NMLS is participating as a members of the task force for examinations and education.

• CFPB is providing assistance via the following:– Documents to Explain the Regulation– Interpreting the Regulation– Providing Implementation Tips– Clarifying Supervisory Expectations

New Mortgage Rules


• NMLS will maintain a library of CFPB and other task force produced “plain English” business guides/documents.

• Compliance video produced on YouTube

Intent: - Minimize confusion and burden of understanding new rules.- Provide uniform interpretation of their meaning.

Timeframe: - Late March/Early April start

New Mortgage Rules

2013 Annual Conference & Training February 26 – March 1 San Antonio, Texas Course Provider Session...

Documents

Transcript of 2013 Annual Conference & Training February 26 – March 1 San Antonio, Texas Course Provider Session...