What amount of tax liens against an mlo would call into question their financial responsibility?

The FAQ is organized by the following categories:

Who | When | How | RMLA | MLO Section | Lines of Credit | Financial Condition | Data Analysis 

For specific questions related to field definitions, please refer to the Standard MCR Definitions and the Expanded MCR Definitions.

WHO

Q. Who is required to complete the MCR?
The MCR is required to be completed by (i) all state licensed companies and (ii) companies employing state licensed mortgage loan originators (MLOs). Review the State MCR Requirements Chart for state-specific details.

Q. What if my company is licensed in a state or has licensed mortgage loan originators in a state and the state does not manage the company license on NMLS – how do we submit the MCR?
The MCR filing capability will allow you to select any state or territory in order to submit data through the system. You may have to manually add these state components to the filing. States not managing company license types on NMLS may not accept this filing as satisfaction of their state reporting requirement. Please check with the state regulator for further information.

Q. What if my company had no origination activity during the reporting period? Do I complete the MCR?
If you held a state license or employed state licensed MLOs during a reporting period, you must complete the MCR. You will be able to indicate that you had no activity during the reporting period and attest to this information. Note that while you may not have had origination activity during the period, all financial condition information must still be reported.

Q. If I am an approved Fannie Mae or Freddie Mac Seller/Servicer or a Ginnie Mae Issuer but I currently don’t service any loans or issue mortgage pools – do I have to complete the MCR?
All state licensed companies or companies employing state licensed MLOs must complete the NMLS Mortgage Call Report even if they have had no activity during the reporting period. Companies that did not have activity during a particular quarter can indicate this on the NMLS Mortgage Call Report.  The system requires companies that have indicated on the MU1 Approvals and Designations Section that they are an approved Fannie Mae or Freddie Mac Seller/Servicer or Ginnie Mae Issuer to complete the Expanded NMLS Mortgage Call Report. Companies should complete either the Expanded or Standard MCR, not both for any period.​

Q. If I am provisionally approved by Fannie Mae or Freddie Mac as a seller/servicer, should I submit the standard or expanded MCR? 
Once Fannie Mae issues you a seller/servicer number, you are required to enter it on the approvals and designations section of the MU1 form. Once that number is issued, you meet the criteria to submit an expanded MCR, and the system will automatically require it.​​

Q. If my institution is only federally-registered on NMLS and we only employ federally-registered MLOs, must we submit the MCR? 
Currently only state-licensed companies and companies employing state-licensed MLOs must complete the MCR.

Q. What if I am a state licensed subsidiary of a federally regulated institution? Do I have to complete the MCR?
All state-licensed companies or companies employing state-licensed MLOs must complete the MCR.

WHEN

Q. If our fiscal year is not calendar year, when do we submit information on the MCR and what period should that information reflect? 
Please refer to "When does the MCR need to be submitted?" for Standard filers and Expanded filers.

HOW

Q. Does NMLS offer a data upload option for the MCR or does it require manual input?
NMLS offers both manual input and data upload options (including the ability to manually edit data that has been uploaded). The data upload feature utilizes XML. For more information, see Mortgage Call Report XML Specification.  There is also an option to upload MLO activity on the RMLA via a comma separated value (CSV) file.

Q. Is there a cost for submitting the MCR?
A processing fee is not charged for filing the MCR.    

Q. My company operates in multiple states. Do I file the MCR for each state?
Only one NMLS Mortgage Call Report is filed per company per quarter. This one report includes a separate break out for each state in which the company is licensed or has licensed mortgage loan originators. This allows you to report the activity you conduct in each state separately.

Q. How do I file the MCR?
The Standard and Expanded MCR must be submitted under the Filing Tab in NMLS. The following quick guides will walk you through creating and completing the Standard and Expanded MCR through NMLS:

Standard MCR - Residential Mortgage Loan Activity

Standard MCR - Financial Condition

Expanded MCR Quick Guide

Q. Is there a limited time that my company has to create or amend MCR filings from previous quarters?
MCRs are unable to be created or amended more than two (2) years after the period end date.  For example, for a Q4 2012 report, the last day it could be created/ amended was on 12/31/2014.

RMLA 

Q. What amount do I report under the application amount – the initial amount on the application or the amount the application closes if it changes?
The initial amount on the application should be used when completing the Application data on the MCR. Starting April 1, 2015, a field has been included to capture changes in application amounts.

Q. What do I report as application amount if the loan was withdrawn or denied prior to the loan amount being known?
Even if no loan amount was applied for prior to the application being withdrawn or denied, if credit is sought, an application amount needs to be included.  For MCR filing purposes $1,000 should be reported for the application amount when the application amount is unknown.

Q. What do we report under Net Changes in Application Amount (decreases should be reflected as a negative)?  Application amounts may have changed from applications received previous quarters and Loans Closed and Funded reported under AC070 for the quarter are not always the same loans reported under Applications Received (AC020) in the quarter.
Here is an example of Net Changes in Application Amount flows within a single quarter or over two plus quarters:

For one loan:
Initial application amount (reported on AC020) when application is received:                 $100,000
Changes to the loan during the quarter (Q1) (report in AC065)                                    - $ 20,000

Each application needs to be tracked and add all the changes for ALL loans into a net figure reported under AC065. If the loan application used in the example above, closes within the quarter, report that change to the loan amount in AC065.

If that loan application moves into the next quarter, it moves over at the lower net amount of $80,000. If another change to the application amount occurs during the following quarter, that change is reported the same way as in the above example for AC065.

For example:
Initial Application amount (reported on AC020) when application is received (Q1):          $100,000
Changes to the loan during the quarter (Q1) (report in AC065) (Already done in Q1)      - $ 20,000
Changes to the loan amount during the quarter (Q2) (report in AC065)                           $ 10,000

If the loan application in the example used above closes in Q2, report the change to the loan amount in AC065.
If that loan app moves into the next quarter, it moves over at the higher net amount of $90,000.

You need to continue tracking the loan amount until the loan closes.

Q. What do I include in the Broker Fee and Lender Fee fields of RMLA Section I?
Include all fees that your company has collected and retained. Examples include, but are not limited to, origination fees, application fees, and yield spread premiums (YSP).  Do not include pass through fees. Note that compensation paid to MLOs is not considered a pass through fee.

Q. When reporting activity information on a RMLA component by state, is this based on the location of the property?
Yes, the activity information is based on the location of the property and reported by state.

Q. Does private money lending for any loan type on the MCR need to be included on the RMLA?
Yes. All residential mortgage loans must be accounted for on the RMLAs regardless of the source of funds.

Q. Does my company have to report loans on unimproved land or construction loans (other than construction-permanent loans) or other temporary financing on the MCR? 
No. These types of transactions are not required to be reported at this time.  As a reminder, construction-permanent loans MUST be reported.

Q. Our company does not collect fees directly from the borrower. Do I have to report fees I receive from someone other than the borrower?
Yes, you must report all fees received, other than pass through fees, regardless of whether they come from the borrower, lender or other party.  At a minimum, these fees are reported in AC600, AC610, AC620 and AC630 as appropriate. 

Q. I do not understand what Sections I, II, or III refer to in the RMLA section. Can you clarify?
Section I collects application, origination, line of credit, revenue and MLO information for the quarter by state. Section II collects more detailed origination information for the quarter by state.  Section III collects servicing related information including modification and delinquency status for the quarter by state. 

Q. How should I report loans in my company’s servicing portfolio that are in forbearance for COVID-19-related reasons, as provided for in the CARES Act?
Where the MCR asks for serviced loans to be reported by delinquency status, report loans according to their true past due date, regardless of whether the loan is in forbearance.

New Servicing and Qualified/Non-Qualified Mortgage Fields

Q. Is my company required to report interim servicing?
No. Interim servicing information under 90 days or collection of three payments or less is not reported on the MCR. 

Q. If my company owns the servicing rights in states where we are not currently required to be licensed through NMLS, should we create state-specific RMLAs in those states to report the servicing activity so all reports balance, or do we report the additional volume under the "Loans Serviced - Nationwide Totals" section?
Your company has two options You can report the servicing activity in the nationwide totals section to reflect the additional servicing volume in those states where you are not required to hold a license through NMLS, but because this won't match up with the state specific servicing figures in the RMLAs, you will be required to acknowledge a completeness check warning and input a note for the regulators. The second option is to create new RMLAs for those states that you are not licensed in, input the servicing data for those respective states, and submit the filing.  This approach will ensure that the nationwide servicing totals match the state specific servicing data, therefore there will be no completeness check warning to acknowledge.   

Q. My company owns the servicing rights to all our loans but uses a subservicer to complete the servicing function.  We have indicated in S540 Subservicing by Others, that all our serviced loans are subserviced by others.  Do we need to report these serviced loans in S600-S1050 as well?
Yes. Your company should report serviced loans in S600-S1050 for loans that you have the servicing rights to.  You need to report on all the loans you are responsible for servicing even if you have contracted with another company (subservicer) to complete that function. 

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