​We are providing this update to keep you abreast of the progress we are making to resolve NMLS performance issues.

The primary ongoing issue we continue to troubleshoot is credit report processing, specifically the Identity Verification (IDV) process. This issue impacts individuals who hold licenses that require a credit report to be requested as part of their renewal request.

Background

The IDV process involves NMLS users answering questions based on their credit history to ensure the credit report vendor pulls the correct credit report. Typically, the IDV process is only completed the first time a user applies for a state license (via the Individual (MU4) Form).

Current issue with IDV process

The IDV is expected to be completed again when an individual's demographic information changes from the last time they completed the IDV. However, as part of the renewal workflow, individuals are not being prompted to go through the IDV process even if it is required.

Current workaround solution  

The workaround is to create an MU4 filing to request the credit report and if the IDV is required to be completed again, the system will prompt users to do so. Once the credit report has been processed successfully through the MU4, users can return to the Renewal section and request license renewal. The renewal request will be completed since the IDV is valid and NMLS will not charge the credit report fees again (credit reports can be re-used for up to 30 days).

We attempted to resolve the uncertainty around when an IDV is required and when it is not by providing a report to company users, but we have received feedback the report is not accurate. As a result, companies are still experiencing problems identifying which individuals need to complete the IDV process.

We understand your continued frustration with this process. We issued the report based on changes evident within NMLS as an indicator that an IDV would be required, however this apparently does not cover the complete list of scenarios in which a new verification is required by the credit reporting vendor. Even with this information, it appears some of the changes to an individual's history are not fields we capture in NMLS.

Again, we apologize for this complication. If we had been aware of the changes in IDV requirements when we migrated to the updated credit reporting platform earlier this year, we would have had an opportunity to communicate proactively.

Thank you for your feedback as we work to improve the renewal experience.