2013 annual conference & training february 26 – march 1 san antonio, texas course provider...
TRANSCRIPT
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
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
• 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: • 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• 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
2013 NMLS Annual Conference & Training | San Antonio, Texas
Education Management System (EMS)
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
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
EMS
Submit PROVIDER NEW & RENEWAL
APPLICATION
Submit PROVIDER NEW & RENEWAL
APPLICATION
Mid May
Submit PROVIDER NEW & RENEWAL
APPLICATION
Submit PROVIDER NEW & RENEWAL
APPLICATION
Submit COURSE RENEWAL
APPLICATION Off
Submit COURSE RENEWAL
APPLICATION Off
Submit NEW COURSE
APPLICATION
Submit NEW COURSE
APPLICATION
Submit NEW COURSE
APPLICATION
Submit NEW COURSE
APPLICATION
May
Submit COURSE RENEWAL
APPLICATION
Submit COURSE RENEWAL
APPLICATION
Periodic Scheduled Outages
PULSE to EMS Transition Timeline
2013 NMLS Annual Conference & Training | San Antonio, Texas
PULSE to EMS Transition Timeline
June
Create COURSE OFFERING
Create COURSE OFFERING
June 24
CREDIT BANKINGCREDIT
BANKING
CREDIT BANKINGCREDIT
BANKING
May
Create COURSE OFFERING
Create COURSE OFFERINGEMS
PULSE
Possible Periodic Scheduled Outages
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• 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
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.
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:
• 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
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
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
2013 NMLS Annual Conference & Training | San Antonio, Texas
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%
2013 NMLS Annual Conference & Training | San Antonio, Texas
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
2012– 518 courses renewed– Renewal rate 60%– Majority of renewal
applications still come in the last week of the month
2013 NMLS Annual Conference & Training | San Antonio, Texas
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%
2013 NMLS Annual Conference & Training | San Antonio, Texas
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
2013 NMLS Annual Conference & Training | San Antonio, Texas
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
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
• 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
Educational Compliance
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
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
Educational Compliance
2013 NMLS Annual Conference & Training | San Antonio, Texas
Key measures: Survey response rate above 20% Scores above 4.0 or 90%
Educational Compliance
2013 NMLS Annual Conference & Training | San Antonio, Texas
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
Educational Compliance
2013 NMLS Annual Conference & Training | San Antonio, Texas
• 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
Educational Compliance
2013 NMLS Annual Conference & Training | San Antonio, Texas
• 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
2013 NMLS Annual Conference & Training | San Antonio, Texas
• 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
2013 NMLS Annual Conference & Training | San Antonio, Texas
• 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