The FAQ is organized by the following categories:
Who | When | How | RMLA | MLO Section | Lines of Credit | Financial Condition | Data Analysis
Q. Will all states adopt the Mortgage Call Report (MCR)?
Consult the State MCR Requirements Chart to find out if filing an MCR is required for the license your company holds. Under the SAFE Act, all mortgage licensees must submit a report of condition in such form and containing such information as required by NMLS.
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).
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 the MCR 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 will be able to indicate this on the NMLS Mortgage Call Report. The system will require companies that have indicated on the MU1 Other Business 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.
Q. I am an approved Fannie Mae or Freddie Mac Seller/Servicer or a Ginnie Mae Issue but I currently do not complete the MBFRF – do I have to complete the NMLS Mortgage Call Report?
All state licensed companies or companies employing state licensed MLOs must complete the MCR even if they have had no activity during the reporting period or have not completed the MBFRF. If your state licensed company (or you are a company employing state licensed MLOs) is a Fannie Mae or Freddie Mac Seller/Servicer or Ginnie Mae Issuer, you must file the Expanded MCR through NMLS. Companies that did not have activity during a particular quarter will be able to indicate this on 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.
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. If our fiscal year is not calendar year, when do we submit information on the MCR and what period should that information reflect?
Information must be submitted within 45 days of the end of a calendar quarter. The activity information must reflect the data from that calendar quarter. For example, if your company submits data on April 1 to reflect 1st quarter information, the data on that report must reflect activity information from January 1st through March 31st. Financial information may reflect your fiscal quarter but it must be noted on the filing that the financial information is not reflective of the calendar quarter. Only companies that do not have a 12/31 Fiscal Year End may avail themselves of this option.
Q. Will NMLS offer manual input or a data upload option for the MCR?
NMLS will offer 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 will not be charged for filing the MCR at this time. The SRR Board of Managers conducts a review of all system processing fees at least annually. SRR will solicit public comment on any fee the SRR Board of Managers has under consideration.
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 report includes break out data for each state in which the company is licensed or has licensed mortgage loan originators.
Q. I don’t see a place for me to file the MCR through NMLS. Where should it be?
The MCR filing option is located under the FILING TAB when you have logged into your COMPANY account. You must be the company account administrator or your company account administrator has assigned you the MCR role as an organizational user.
Q. What do you mean by “application” for the MCR?
Application is defined in the MCR as “an oral or written request for a home purchase loan, a home improvement loan, or a refinancing that is made in accordance with procedures used by a financial institution for the type of credit requested.” The NMLS Mortgage Call Report primarily relies on the Reg. B use and definition of application and generally follows HMDA reporting requirements.
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.
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 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.
Lines of Credit
Q: Why is LOC information no longer on the state-specific RMLA?
LOC information is often not state-specific. This information was removed from the state-specific RMLA and added to a new company-level RMLA. The information reported on the company-level RMLA will be shared with all agencies with which you hold a license.
Q. How do we report warehouse lines of credit?
Currently, you must list your warehouse lines of credit on the company level information section of the MCR. each RMLA. The lines of credit should reflect all lines of credit the company holds.
Q. How do I report my MLOs on the MCR?
You must enter the NMLS ID of the MLO along with the dollar amount and count of the closed residential loans that MLO originated during the reporting period. If the MLO had no activity, you would enter zeroes in the amount and count fields but the MLO must be listed for each state they hold a license.
Q: Must the MLO information be entered manually?
No, the MLO information can be uploaded in conjunction with the XML upload or a be uploaded via a comma separated value (csv) upload file.
Q. What if my company had no MLOs during the reporting period?
When making the MCR filing, you will have the opportunity to enter information for any of your state licensed MLOs. If you do not have any state licensed MLOs during a reporting period, you would leave this section blank and attest to the filing before submission.
Q. How does my company report our MLOs on the MCR?
When reporting the MLOs with their closed loan information, you must report the MLOs operating in each state. For example, if one of your MLOs had closed loans in two states during a quarter and also operated in a third state but had no closed loans during that quarter, you will list that MLO in each of those three state RMLA components. The first two state RMLA components will contain the MLO's name and NMLS ID # with a loan dollar amount and loan count greater than zero and the third state will have the MLO's name and NMLS ID # with zero in the loan dollar amount and loan count fields.
Q. What if we no longer employ a MLO but did in the reporting quarter - do we list them on the MCR?
Yes. You must list each MLO you employed during the reporting quarter in each state whether or not you employ the MLO when you submit the MCR filing.
Q: Why is C800 calculating differently in Form Version 2?
The calculation for C800 was corrected in form version 2, the calculation was updated to: C800 = C090 + C260 + C450 + C650 + C780.
Q. Why am I receiving a data validation warning on the FC?
The text for the data validation warning in the system will be updated to read:
The absolute value of D320 must equal the absolute value of C800 – C160 – D310.
The presence of a warning does not prevent submission of the MCR. If you encounter this warning message and have verified the information you entered is correct, you should enter this in the Explanatory Note Field:
We have reviewed the warning message related to D320 and C800 and have verified that the information submitted on this filing is accurate.
If all other completeness checks and warning messages are cleared, you will be able to mark the FC component as Ready to Submit.
Q. I have not filed my taxes yet and won’t complete them until April 15th. How can I complete the FC?
The deadline for the FC is 90 days from your fiscal year end. You must provide complete information in a timely manner to your state regulator. Failure to file on time will result in a deficiency placed on your company license.
Q. My company earns revenue from sources other than mortgage origination. I don't see a place to enter this information - what should I do?
Currently there is no field on the FC to report non-origination income. This will be added in a future upgrade.
Q. If I don’t receive fees directly from the borrower, do I have to complete fields related to this topic (e.g. C210, C220, C230)?
The definitions do not limit this information to borrower received fees.
Q. What does FAS stand for and where do I find this information?
FAS stands for Financial Accounting Standards and refers to specific guidance provided by the Financial Accounting Standards Board (FASB)
Q. The terms and definitions are not familiar to me as an industry user. Can you please clarify how this applies to me as a member of the mortgage industry?
The terms and definitions for the FC are based on the terms and definitions used in the Mortgage Bankers Financial Reporting Form (MBFRF) – a document used throughout the mortgage industry.
Q. I am unclear what A010 – Cash and Cash Equivalents, Unrestricted means. Can you clarify?
Paragraphs 7 & 8 of FAS 95 help define this term. For cash equivalents, common examples include Treasury bills, commercial paper, money market funds, and federal funds sold (FAS 95 paragraph 9).
Q. I already submit the RMLA, why do I have to submit the FC?
The RMLA and FC are both components of the NMLS MCR requirement. One component provides information on loan activity and the other provides information on the financial condition of your company.
Q. My company already submits a financial statement through NMLS. Why do I have to submit the FC?
The financial statement and financial condition component constitute different requirements. In the future, the system will accommodate a FC submission to satisfy a state’s unaudited financial statement requirement.
Q. We are unsure what to enter for non-corporate personnel compensation under Schedule D. Can you provide general clarification?
This section requires your company to report compensation expenses (salaries, etc) paid to individuals serving in an origination, secondary marketing or warehousing capacity.
Q. Will the FC filing accept decimals or negative values in fields?
Each section of the FC provides clear direction on how values must be entered. You can refer to MCR Data Formatting Guide for instructions.
Q. I am confused with C200. Do I report values for my mortgage business, my real estate business or my other businesses?
This section refers to originations-related non-interest income; and if your company uses fair value accounting for loans held for sale
Q. My company files consolidated financial statements either through the MBFRF or to state agencies. May we use these for the NMLS Mortgage Call Report?
No. The financial condition component of the NMLS MCR must be reflective of the licensee and not “rolled-up” or consolidated information of the parent company.
Q. Will the MCR be made available to the public?
Company specific reports will not be made publicly available. Aggregate data may be released to the public at a future date.
Q. What happens to my data once it is submitted?
NMLS will process the data and release reports to state regulators on the submitted data. State regulators may also review individual company Mortgage Call Report filings within the system.
Q. Will the MCR replace all state annual or quarterly reports?
One goal of the NMLS Mortgage Call Report is to standardize and improve the information available about mortgage originations such that it can replace currently required state reporting. The decision is up to each state agency and many states have indicated that they will accept the NMLS Mortgage Call Report as satisfaction of their state specific reporting requirements. Contact your state regulator for complete information.