The NMLS renewal window opens this Saturday, November 1st. Are you ready to submit your renewal requests? Here are some things to keep in mind:
- Renewal should be about fee collection and re-verification that the information associated with your license is up to date. However, many jurisdictions take this opportunity to perform “clean up” duties that they haven’t had the time to focus on throughout the year. Act early to make sure that you have taken care of any remaining license items (deficiencies) on your NMLS record. If you thought you had taken care of that license item from June and it is still there, now is the time to follow up with your regulator to see if the information wasn’t complete or was misdirected within the agency.
- Before you submit a renewal request make sure that you have reviewed the public renewal checklist for your jurisdiction(s) that is found on the NMLS resource center. Agencies are still in the process of finalizing these documents so make sure that you double check (or sign up for NMLS’ handy RSS feed feature) before you attest. This is especially important for jurisdictions that have a certain order in which renewal items must be submitted. For example, you want to make sure that your MLOs have actually completed (not just scheduled) any jurisdiction-specific Continuing Education hours before they submit a renewal request so that they aren’t making a false attestation.
- If at all possible, do not submit an amendment right before or right after you submit your renewal request. Certainly you want to make sure that your record is accurate before you attest and submit a renewal request, but an amendment in conjunction with renewal could be a red flag to hold your renewal request for additional scrutiny.
- Do you know what your jurisdiction(s) suggested renewal submission date is? This may not be tied to any statutory basis, but many jurisdictions now give a date by which renewal requests should be submitted to be considered timely and to ensure that the state has time to review and process. West Virginia recently updated their NMLS Renewal Checklist to show a date of close of business on November 3, 2014 for renewal requests submitted in a complete format to be considered timely and to guarantee review of the renewal will be completed prior to license expiration on December 31st. And yes, November 3rd is the first business day after the renewal window opens. Additionally, the call center isn’t open on the weekend if you have issues submitting your request.
- How do you plan on paying for your renewal? Although processing times are improving, paying via ACH will still result in a “funds pending” deficiency being placed on your renewal request, which automatically delays its review until that deficiency clears the system. Credit card fee payments process through the system quicker but contain an additional processing fee.
- Are you prepared to handle any additional requirements that may be placed after you submit your renewal request? Paying your fee and attesting isn’t the end of the process. Make sure you have a process in place to monitor requests from regulators that may follow a renewal submission either through the NMLS or via electronic mail. Timely handling any additional items increases your chances of having your renewal approved before your current license expires.
- Don’t panic if your renewal request isn’t approved right away. Some jurisdictions will utilize NMLS’ auto-renewal feature to help with their workload. If you don’t have any outstanding items on your record it could still take up to 14 days for your renewal to be moved to approved in the system. If you have no deficiencies or other items on your record, wait at least that long before attempting to reach out to the jurisdiction to see if there are any issues for you to take care of. Remember, the majority of jurisdictions will process renewals the same way they process new license and amendment requests, in the order that they are received. That is why it is still to your benefit, if you can, to make sure to submit your requests early in the renewal window. Additionally, some states have procedures in place that they will not take the time away from renewal review to respond to any status update inquiries during the renewal period.
- Do you know what your jurisdiction’s policies are with respect to renewal requests that aren’t approved on or before licenses expire on December 31st? Now is the time to make sure that you are familiar with whether or not you or your MLOs can continue business as usual while you wait for a regulator decision or whether you will need to have a plan in place to stop business in a certain jurisdiction until a decision is made on your renewal request. The NMLS has a license-specific renewal information page.
- Do you have a pending license application that hasn’t been approved yet? If the regulator approves it on or before November 1st it will need to be renewed. Any application approved after November 1st will look like it is effective in the system through 2015, but be sure to check specific jurisdictional requirements. Some jurisdictions do not have statutory authority to grant a license that is good for more than 12 months and you will have to renewal that license outside of the system in order to continue conducting business after December 31st.
The main thing to remember as you enter the renewal process is that while you handle renewal for your company, the regulator has to process renewal requests for hundreds of licensees. Making sure your renewal is complete and submitting early make the renewal process more efficient for all parties involved. If however, you find that lingering issues affect your renewal, don't wait to get legal counsel involved so that issues can be mitigated before your current license(s) expire