1. Vermont Department of Financial Regulation

2. Cynthia Stuart Sue Clark Ned Pike Deputy Commissioner of Banking
Regulatory & Consumer Affairs Director
Ned Pike
Senior Financial Examiner

3. Topics to Explore Cynthia Stuart, deputy commissioner of banking
Department of Financial Regulation Overview
Who Does the Banking Division Regulate?
Vermont Foreclosure Trends
NMLS Update
Advertising & Social Media
Examination Process
Q & A

4. Department of Financial Regulation
Captives
Division
Deputy
David Provost
Commissioner Michael Pieciak
Banking
Division
Deputy
Cynthia Stuart
Insurance
Division
Deputy
Kaj Samson
Securities
Division
Deputy
William Carrigan

5. Who does the Banking Division regulate?

6. Who does the Banking Division regulate?

7. Mortgage Loan Originator Licenses
Vermont MLOs
2016
1935
2015
1700
2014
1265
2013
1301
2012
1004
2011
851
2010
633

8. New Foreclosure Filings

9. NMLS UPDATE Electronic Surety Bonds Criminal Background Checks (CBC)
Individual Document Upload
NMLS 2.0 Guiding Principles

10. ELECTRONIC SURETY BONDS
Vermont is one of nine states accepting surety bonds electronically through NMLS
Functionality is designed for Company, not Branches
Transition of existing surety bonds
Money Servicers & Debt Adjusters – 11/1/2016
All Other Licensees – 7/1/2017

11. CRIMINAL BACKGROUND CHECKS (CBC)
Allows States to require CBC for any MU2 Individual
Vermont requires CBC
Qualifying Individuals & Branch Managers
Executive Officers – CEO, President, CFO, COO, CIO, CCO
Direct Owners of 10% or more
Indirect Owners of 25% or more
Process is a two steps process
Companies must grant CBC Agency Access by State
Individuals authorize the CBC

12. INDIVIDUAL DOCUMENT UPLOAD
Document upload capability for state individual filings (MU2 and MU4)
Vermont Tax Certification

13. NMLS 2.0 Guiding Principles
Real Time System
Uniform Data
Legal System of Record
Automation

14. ADVERTISING
Vermont Statutes
Other Names
Responsibility

15. VERMONT STATUTES 8 V.S.A. § 2244 Unique Identifier
The unique identifier issued by the NMLS of any person shall be clearly shown on all loan application forms, solicitations, or advertisements, including business cards or websites, and any other documents.
8 V.S.A. § 2228 Other Names or Business Places
No licensee shall transact such business or make any loan provided for by this chapter under any other name or at any other place of business than that named in the license.

16. OTHER NAMES
NMLS #ID issued to an individual, is not a team, and correlates to a mortgage loan originator license
NMLS #ID issued to a company correlates to various functional licenses (Lender License, Mortgage Broker License), each authorizing the company to transaction business using a specific name at a specific address
If a Company wishes to advertise using another name for branding, such as “The Jane Doe Team,” then it is must apply for a license to use the name at the location(s) where it intends to transact business

17. RESPONSIBILITY
Establish a policy for advertising that includes websites, periodic advertising, and social media
Review all advertisements before publication and periodically
Follow-up with third party contractors that design websites or provide platforms, i.e. Facebook or Linked In

18. Examination Process Ned Pike, Senior Financial Examiner
Multiple Licenses – In an effort to streamline the examination process, if an entity holds multiple Vermont licenses, DFR will attempt to examine all licenses at the same time.
Increased focus on:
Management actions
Financial Capacity
Internal Controls/Audit/Quality Control

19. Examination Process
Initial Request Letter – An initial request letter sent is sent to a licensee with a two to three week timeframe to produce a loan lists. Licensee should be collecting other requested data during this period for presentation at on-site examination.
Loan Review & Exam Scheduling - The examiner-in-charge will select loans from the received list for review. A proposed on-site examination date is also sent to licensee with a minimum of two weeks advance time, but timing will depend greatly on examiner scheduling.

20. Examination Process
On-site Examination – The on-site examination will go relatively quickly for Lender and Broker Licenses. Loan Servicer Licenses often require additional time.
Examination Results – The goal is to have a completed examination report mailed to the licensee within 30 days of the on-site contact or exit conference call (whichever is later).

21. Examination Process
Examination Licensee Response – The Vermont statutory requirement is for a licensee to respond within 30 days of receipt of the examination report.
Response Review - The Examiner-in-Charge will assess the received examination response. If satisfactory, examination is closed. If not satisfactory, the exam and response is referred to Director and Deputy Commissioner.

22. ADDITIONAL POINTS Drop Box – New!
Encrypt / Password Protect Through Winzip
Escrow Issues – Always an area of review for compliance with Vermont requirements.
New TRID Compliance – DFR is reviewing for attempt to comply with focus on assisting industry to comply.
Commitment Letter Regulation & TRID
Mortgage Broker Contracts
Reverse Mortgages

23. Q & A