Recent Changes to Illinois Registration Fees and NMLS Requirements

by: Nicole Legere

The Illinois Division of Banking recently adopted several changes to the registration fee requirements for loan originators. These changes included the addition of an exempt entity registration fee. There were also requirements added regarding the use of the Nationwide Mortgage Licensing System (NMLS) unique identifier on various loan documents. The new requirements became effective on December 27, 2013.

Residential Mortgage Licensing Fees

Applicants for licensure must pay an annual registration fee of $2,700 dollars which is a $657 dollar increase from the previous fee of $2,043 dollars. This fee is broken down into an investigation fee and initial application fee. The applicant must pay a $1,500 dollar non-refundable investigation fee which is an increase from the prior fee of $1,135 dollars. The applicant must also pay an initial license fee of $1,200 dollars which is an increase from the prior fee of $908 dollars. These fees can be paid separately or as a singular combined fee based on the discretion of the Director of the Division of Banking. Applicants for license renewal will face the same overall increase in fees as the annual licensing fee is being raised to $2,700 dollars.
The Division also added an exempt registration fee of $2,700 dollars for applications submitted by entities authorized under Section 1-3(a-1) of the Residential Mortgage License Act of 1987. This section allows federally chartered organizations, who are exempt from licensure, to sponsor those individuals serving as loan originators for registration. “A person who is exempt from licensure … as a federally chartered savings bank that is registered with the Nationwide Mortgage Licensing System and Registry may apply to the Secretary for an exempt company registration for the purpose of sponsoring one or more individuals subject to the mortgage loan originator licensing requirements of Article VII of this Act.”

NMLS Requirements

There were also changes made to the requirements surrounding the use of the mortgage loan originator NMLS number on the loan brokerage agreement and origination logs. Previously, these documents had been required to contain the originator name and registration number. This change will result in use of a nationwide identifier rather than the Illinois Department of Financial and Professional Regulation (DRPR) state identifier.

The licensing fee requirements can be read in full at: ftp://www.ilga.gov/JCAR/AdminCode/038/038010500B02100R.html

The NMLS requirements can be read in full at: ftp://www.ilga.gov/JCAR/AdminCode/038/038010500I10100R.html
ftp://www.ilga.gov/JCAR/AdminCode/038/038010500J11750R.html

About the Author
Nicole Legere, J.D. is a Senior Regulatory Compliance Consultant at Bankers Advisory, Inc. She is a graduate of the University of Massachusetts at Amherst and earned her Juris Doctor at Roger Williams School of Law. Nicole is admitted to the Bar in Massachusetts and New York.   She can be reached at nicole@bankersadvisory.com