QUESTION
As a
stateside licensed mortgage lender in many states, I am frustrated with the
process of managing the examination process. Are there any plans in place to
streamline the process?
ANSWER
Back in
August of 2012, the CSBS Technology Task Force prepared a proposal which
introduced the NMLS Examination Management Tool Suite (EMTS). In the interim,
the CSBS EMTS State Regulator Working Group was staffed and an Executive
Steering Committee was formed to oversee the requirements phase, vendor
selection and development. The SRR Board approved the Request for Proposal
(RFP) which was issued in July of 2015. The purpose of the initiative is
defined as the development of a full-service examination
management suite of tools for state agency use for single, multistate, and
state/federal non-depository examinations while aligning with, to the fullest
extent practicable, the examination tool being developed by CFPB.
The tool must incorporate a federated-type system of management between
CSBS and the individual state agencies while maintaining autonomy of use by
each participating state agency. Specifically, the tool must be housed within
NMLS and go beyond the mortgage space by including Money Service Businesses and
other non-depository entities. The tools must also work equally well for both
single-state and multi-state supervision.
The system was designed to solve three major business problems:
- Current state systems for examinations do not allow for efficient collaboration among state agencies and/or with federal agencies.
- Multistate supervisory efforts, such as the Multistate Mortgage Committee (MMC) and the Multistate MSB Examination Taskforce (MMET) require a coordinating system to fully realize their goals of improved supervision and efficiency for licensees.
- Not all current systems provide licensees with an efficient and secure manner to exchange documents and communicate with one or multiple regulators.
The functional pieces of the system are categorized as Primary or SPrimary
functions are those activities that are directly focused on creating and
delivering an examination product or service. Some of the elements include core
examination management functions such as selection of the examinee, the scope
and schedule of the exam, information requests, conducting the exam itself, the
examinee portal and post exam activities.
The support functions
and systems are defined as activities and systems used by one or more primary
functions to improve their effectiveness and efficiency. Examples include data integration and security, workflow and document
management, system integration, security and access control, workflow and
document management and reporting, to name a few.
Finally, what are the benefits or
deliverables that will be provided by the system? The system will:
- Enhance the uniformity and efficiency of the single state, multi-state and CFPB coordinated exams as many states do not have a complete examination system;
- Drive the building of best practices for examination processes for states and CFPB;
- Promote consistent terminology, standard workflows and facilitate data sharing between a CFPB and state system where possible;
- Allow state agencies to retain depository examination materials in a secure manner so that they can be used for future work; and
- Provide a secure portal to exchange examination communications and documentation between the examiner and examinee.
At this time, a thorough, on-going RFP review process is in place and a system implementation plan is being developed. You will be hearing more about the progress of this initiative in the coming months.
Alan Cicchetti
Director/Agency
Relations
Lenders
Compliance Group
Executive
Director
Brokers
Compliance Group
