Educational Compliance

Report
2013 Annual Conference & Training
February 26 – March 1
San Antonio, Texas
Course Provider
Session
Pete Marks, VP, SRR
Rich Madison, S. Director, SRR
Agenda
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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
2013 NMLS Annual Conference & Training | San Antonio, Texas
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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Activities
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Course Provider Approval/Renewals
Course Approvals/Renewals
Technical Support – credit banking, systems
State Regulator Support
Policies
Vendor Management
New EMS Build
2013 NMLS Annual Conference & Training | San Antonio, Texas
Education Management System (EMS)
SRR’s existing contract with Pearson for education ends
in June 2013. In response:
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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)
2013 NMLS Annual Conference & Training | San Antonio, Texas
Education Management System (EMS)
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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Education Management System (EMS)
– 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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Education Management System (EMS)
- 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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Education Management System (EMS)
- 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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Education Management System (EMS)
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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Education Management System (EMS)
- Central Education Data Depository
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Import and Host Exiting MLO Education Data from Pearson
Data Validation
- Redesign of Course Completion Record (transcript)
- Reporting
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Course Level
State Level
Data Analytics
Custom
2013 NMLS Annual Conference & Training | San Antonio, Texas
Education Management System (EMS)
Enhanced Provider Services:
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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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Education Management System (EMS)
2013 NMLS Annual Conference & Training | San Antonio, Texas
Education Management System (EMS)
• View all your
courses in one list
• View details of one
course record
2013 NMLS Annual Conference & Training | San Antonio, Texas
Education Management System (EMS)
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
2013 NMLS Annual Conference & Training | San Antonio, Texas
PULSE to EMS Transition Timeline
EMS
Submit PROVIDER
NEW & RENEWAL
APPLICATION
May
Submit NEW
COURSE
APPLICATION
Submit COURSE
RENEWAL
APPLICATION
Mid May
Periodic Scheduled Outages
Submit PROVIDER
NEW & RENEWAL
APPLICATION
Submit NEW
COURSE
APPLICATION
PULSE
2013 NMLS Annual Conference & Training | San Antonio, Texas
Submit COURSE
RENEWAL
APPLICATION Off
PULSE to EMS Transition Timeline
Create COURSE
OFFERING
EMS
May
June
Create COURSE
OFFERING
Possible Periodic Scheduled Outages
PULSE
2013 NMLS Annual Conference & Training | San Antonio, Texas
CREDIT
BANKING
June 24
CREDIT
BANKING
New Course Completion Record (PE)
2013 NMLS Annual Conference & Training | San Antonio, Texas
New Course Completion Record (CE)
2013 NMLS Annual Conference & Training | San Antonio, Texas
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
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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
2013 NMLS Annual Conference & Training | San Antonio, Texas
New Education Compliance Tracking
2013 NMLS Annual Conference & Training | San Antonio, Texas
New Education Compliance Tracking
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 completed
CE they will have to meet the new requirement.
2013 NMLS Annual Conference & Training | San Antonio, Texas
New Education Compliance Tracking
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:
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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.
2013 NMLS Annual Conference & Training | San Antonio, Texas
New Education Compliance Tracking
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.
2013 NMLS Annual Conference & Training | San Antonio, Texas
By the Numbers…
2013 NMLS Annual Conference & Training | San Antonio, Texas
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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Approved Course Breakdown
2011
1239 approved courses
389 PE Courses
48% of these are PE
Comprehensive
850 CE Courses
28% of these are CE
Comprehensive
92 Active Late CE Courses
2013 NMLS Annual Conference & Training | San Antonio, Texas
2012
1151 approved courses
333 PE Courses
42% of these are PE
Comprehensive
818 CE Courses
28% of these are CE
Comprehensive
86 Active Late CE Courses
Credit Banking
2011
1,478,366 hours banked
42% PE
57 % CE
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Delivery Method
Classroom – 24%
CEQ – 10%
OIL – 24%
OSS – 42%
2013 NMLS Annual Conference & Training | San Antonio, Texas
2012
1,676,261 hours banked
45% PE
55% CE
Delivery Method
• Classroom – 23%
• CEQ – 6%
• OIL – 21%
• OSS – 50%
2012 Course Delivery Breakdown
753,981 PE Hours
2013 NMLS Annual Conference & Training | San Antonio, Texas
2012 Course Delivery Breakdown
922,280 CE Hours
2013 NMLS Annual Conference & Training | San Antonio, Texas
Course Renewals
2011
– 496 courses renewed
– Renewal rate 62%
– 80% of course renewal
submissions occur on
the last day of the
month
2013 NMLS Annual Conference & Training | San Antonio, Texas
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%
2013 NMLS Annual Conference & Training | San Antonio, Texas
2012
• 165 Approved Course
Providers
• 27 Providers Renewed
• Renewal Rate of 50%
Course Approval Process
• Good but can be frustrating at time
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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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Course Approval Process
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2013: Emphasis on Instructional Design and Quality
We encourage innovation
Forum for Best Practices
Course tips:
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Most common mistake: citations are not current
Note changes on resubmission
No final assessment
No case study
2013 NMLS Annual Conference & Training | San Antonio, Texas
Education Compliance…
2013 NMLS Annual Conference & Training | San Antonio, Texas
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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Educational Compliance
• 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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Educational Compliance
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.
2013 NMLS Annual Conference & Training | San Antonio, Texas
Educational Compliance
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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Educational Compliance
Key measures:
Survey response rate above 20%
Scores above 4.0 or 90%
2013 NMLS Annual Conference & Training | San Antonio, Texas
Educational Compliance
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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Educational Compliance
• 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
2013 NMLS Annual Conference & Training | San Antonio, Texas
CFPB & New Mortgage Rules…
2013 NMLS Annual Conference & Training | San Antonio, Texas
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
2013 NMLS Annual Conference & Training | San Antonio, Texas
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
2013 NMLS Annual Conference & Training | San Antonio, Texas
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
2013 NMLS Annual Conference & Training | San Antonio, Texas

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