The NMLS Policy Guide has recently been updated to clarify the changes regarding the Temporary Authorization to Operate. Specifically, the guide added the definition “Temporary Operating Authority” to the glossary, added the statutes of the Temporary License Authority to the “Definition of license status” list, and added a new section titled “Non-communicable events and regulatory actions”.
The Temporary Authorization to Harness Consumer Access section has been updated to explain that Consumer Access will update an MLO’s status to “Authorized to Represent” once sponsorship is requested or accepted. The definition of “Temporary Operating Authority” has been added to the glossary section to explain that the temporary authorization to act as principal allows some MLOs to initiate loans while meeting specific requirements for the State for the license to practice.
The update adds four temporary permissions to use license statuses to the “License Status Definition” list. Generally, the statutes are as follows:
- Pending-Deficient (Temporary Authority Eligible) indicates that the request is pending a criminal background check or sponsorship request;
- Pending-Deficient (Temporary Authority) indicates that the request is pending testing and training or a license item;
- Awaiting Review (Temporary Authorization) indicates that the application is pending regulatory review and decision; and
- Pre-approved (temporary authority) indicates that the applicant has met all other requirements and the application is approved, but the testing and training requirements are incomplete.
The new section “Undisclosed Events and Regulatory Actions” explains that when regulatory actions are published in the NMLS with the confidentiality level “All actions to be disclosed.