CHLA Proposes Streamlining the State Examination Process for Independent Mortgage Banks
Letter Recommends a Uniform Annual Exam to be Implemented in Congruence with CSBS
(Washington D.C.) – The Community Home Lenders of America (CHLA) sent a letter to the Conference of State Bank Supervisors (CSBS) proposing a collaboration to enhance state examination procedures for Independent Mortgage Banks (IMBs) by streamlining the process into one Uniform Annual Exam.
CHLA recommends that CSBS take a “Streamlined Examination Process” approach which would allow IMBs to “annually submit application logs, management questionnaire responses, marketing materials, and policy samples. State regulators would then have the flexibility to examine each IMB as needed. If additional items are required, a formal inquiry could be initiated using a process akin to the NMLS Licensing condition process.”
The letter also proposes a variety of enhancements to the National Multistate Licensing System (NMLS) to increase productivity and regulatory oversight. The enhancements include:
- Document Attachment for NMLS License Conditions
- Attachment of Written Responses to NMLS Licensing Conditions
- Implementation of Timed Responses
The CHLA letter closes with reaffirmation of support for CSBS, stating that “We are committed to working with CSBS and its state members to establish parameters that promote a balanced regulatory framework—one that preserves the diversity and competitive edge of small lenders while safeguarding the interests of consumers. By doing so, we can collectively strengthen the financial landscape, encourage innovation, and uphold the principles of consumer choice, affordability, and accessibility in the mortgage lending industry.”