It’s that time of the year again. For the new kids on the block, make sure you are ready for your NMLS renewals.
NMLS renewal begins on November 1st and, for most states, it will go through December 31st, with a few exceptions like Idaho due on November 30th or Wisconsin due December 1st, among others. Make sure to review the Renewal Deadlines, Requirements, Fees Chart and mark your calendar. Keep in mind that the various state departments are short staffed and, at this time of the year, will be reviewing many renewal applications. Be organized and courteous by providing your renewal request ahead of the renewal deadline, this will allow the examiners time to review, ask follow up questions, and approve your license prior to its expiration. Late submitters may not be able to conduct money transmitter activity in the upcoming year until their licenses are re-instated.
As a first step, assure that your company and officers’ records (MU1 and MU2) are up-to-date. Remind each officer to check their information and make any necessary adjustments. Review the company data and submit any amendments prior to November 1st – is there a new management chart? Perhaps a new AML Policy? In addition, review your company dashboard and respond to any open items. Are all your licenses eligible for renewal? Sometimes outstanding exam invoices can prevent you from renewing your license.
Renewal checklists are already available NOW. Download the checklists (2016 Renewal Checklists) and get familiarized with them. Ensure that your internal teams are aware of what is needed from each of them and they understand the internal deadlines. Certain documents can be requested ahead of time, such as good standing certificates, proof of bond in force or a rider, among others.
For those with licenses in the majority of the states, we suggest you to submit your renewals in batches, giving you time to carefully upload certain documents, while mailing others. Documents required by the states to be submitted outside the system must be submitted to the specific agency within five business days of the electronic renewal submission via the NMLS. The NMLS document upload guide should be reviewed prior to starting the application process and will help you upload documents to the correct area.
Prior to being able to complete the submission for renewal, a licensee will need to pay the renewal fees via the NMLS system. While state fees vary, all licensees pay a $100 NMLS fee per state license being renewed. Payments can be maybe via ACH or credit card (Visa and MasterCard) – transactions that are paid by credit will have a service fee of 2.5 percent added to them. ACH payments require a one-time pre-authorization from your bank, which needs to be completed prior to using this method of payment – provide NMLS vendor information to your bank. In regards to authorized delegate locations, some states will be able to invoice you via the NMLS system, while others will request you to send a check.
If you are not renewing a state license, you can mark the license as “Do Not Renew” by selecting the checkbox next to the corresponding license. However, state regulators may require additional information be sent outside of the NMLS system.
After submission of your licenses, be on the alert for emails from the NMLS system or make a habit of checking your company dashboard for follow-up requests from states. Through the NMLS website, regulators will keep you posted on the status of your application – under review, deficient, or approved.
Remember, regulators are always willing to help and open for questions. Chartwell expert staff is also available to help you succeed and guide you through this renewal season.
* Licensees will pay an additional annual processing fee, per license to NMLS (Company-$100, Branch-$20, Individual-$30).
Trish Lagodzinski has more than 19 years of experience in government contracting, project management and support. At Chartwell Compliance and, previously, Ascella Compliance, she has assisted with regulatory compliance matters dealing with state money services business licenses and related state and federal compliance regulations for a wide range of non-bank financial services companies. Her work has included leading a 50-state license application project in six months for a publicly traded customer. She also serves as an outsourced state license administrator for customers. For more information please contact Trish Lagodzinski at firstname.lastname@example.org.
Jennifer Naudin, J.D. is a Senior Compliance Analyst with Chartwell Compliance, where she focuses on state money transmitter licensing. She is a former Compliance Analyst for ADP, Inc., and has 9 years of experience in compliance, lending and money transmission licensing. For more information please contact Jennifer at email@example.com.
Cristiane Fernandes has over 5 years of experience working in the payments industry and previously worked in Blackhawk Network’s Legal Department where she was involved in obtaining Blackhawk’s 46-states, plus the District of Columbia and Puerto Rico money transmitter licenses. For more information please contact Cristiane at firstname.lastname@example.org