Legal Seminar, Chicago, IL

Streamlining MLO Licensure Data supports streamlining MLO licensing. A 2016 study found that: • 93% of all applications are ultimately approved by state agency, including: • 40% were “clean” (no CHRI, credit flags, no disclosures) • 60% were “unclean” (at least one of above) • Criminal history review is not different between banks and state regulators. Applications with CHRI: 90% approval rate:

• State-to-state: 90% approval • Fed-to-state: 90% approval • Median turn times show current system is not risk-based: • All Applicants: 18 days • Currently Licensed MLOs: 17 days

Streamlining MLO Licensure: CHRI Review Period For TA eligible licenses, the applicant state will have a limited time to complete the RAP sheet review.

• During this review period, the state agency must receive adequate response to the request for clarification. • If the agency does not receive an adequate response, it will be incumbent on the agency to take action (e.g., intent to deny) to end TA eligibility. • If the applicant remains in the TA eligible status at the end of the 9 business day review period, the system will update the status to TA granted.

• If the applicant has a RAP sheet, the state agency will be given 2 business day to review the CHRI. • If the state agency requests additional information from the applicant, posting a “CBC” license item will extend the review period to 9 business days total. • If a license item is not posted, at the end of the 2 business day period, the system will update the status to TA.