The FAQ is organized by the following categories:
Who | When | How | RMLA | MLO Section | Lines of Credit | Financial Condition | Data Analysis
Q. Who is required to complete the MCR?
The MCR is required to be completed by (i) all state licensed companies and (ii) companies employing state licensed mortgage loan originators (MLOs). Review the State MCR Requirements Chart for state-specific details.
Q. What if my company is licensed in a state or has licensed mortgage loan originators in a state and the state does not manage the company license on NMLS – how do we submit the MCR?
The MCR filing capability will allow you to select any state or territory in order to submit data through the system. You may have to manually add these state components to the filing. States not managing company license types on NMLS may not accept this filing as satisfaction of their state reporting requirement. Please check with the state regulator for further information.
Q. What if my company had no origination activity during the reporting period? Do I complete the MCR?
If you held a state license or employed state licensed MLOs during a reporting period, you must complete the MCR. You will be able to indicate that you had no activity during the reporting period and attest to this information. Note that while you may not have had origination activity during the period, all financial condition information must still be reported.
Q. If I am an approved Fannie Mae or Freddie Mac Seller/Servicer or a Ginnie Mae Issuer but I currently don’t service any loans or issue mortgage pools – do I have to complete the MCR?
All state licensed companies or companies employing state licensed MLOs must complete the NMLS Mortgage Call Report even if they have had no activity during the reporting period. Companies that did not have activity during a particular quarter can indicate this on the NMLS Mortgage Call Report. The system requires companies that have indicated on the MU1 Approvals and Designations Section that they are an approved Fannie Mae or Freddie Mac Seller/Servicer or Ginnie Mae Issuer to complete the Expanded NMLS Mortgage Call Report. Companies should complete either the Expanded or Standard MCR, not both for any period.
Q. If my institution is only federally-registered on NMLS and we only employ federally-registered MLOs, must we submit the MCR?
Currently only state-licensed companies and companies employing state-licensed MLOs must complete the MCR.
Q. What if I am a state licensed subsidiary of a federally regulated institution? Do I have to complete the MCR?
All state-licensed companies or companies employing state-licensed MLOs must complete the MCR.
Q. If our fiscal year is not calendar year, when do we submit information on the MCR and what period should that information reflect?
Please refer to "When does the MCR need to be submitted?" for Standard filers and Expanded filers.
Q. Does NMLS offer a data upload option for the MCR or does it require manual input?
NMLS offers both manual input and data upload options (including the ability to manually edit data that has been uploaded). The data upload feature utilizes XML. For more information, see Mortgage Call Report XML Specification. There is also an option to upload MLO activity on the RMLA via a comma separated value (CSV) file.
Q. Is there a cost for submitting the MCR?
A processing fee is not charged for filing the MCR.
Q. My company operates in multiple states. Do I file the MCR for each state?
Only one NMLS Mortgage Call Report is filed per company per quarter. This one report includes a separate break out for each state in which the company is licensed or has licensed mortgage loan originators. This allows you to report the activity you conduct in each state separately.
Q. How do I file the MCR?
The Standard and Expanded MCR must be submitted under the Filing Tab in NMLS. The following quick guides will walk you through creating and completing the Standard and Expanded MCR through NMLS:
Standard MCR - Residential Mortgage Loan Activity
Standard MCR - Financial Condition
Expanded MCR Quick Guide
Q. Is there a limited time that my company has to create or amend MCR filings from previous quarters?
MCRs are unable to be created or amended more than two (2) years after the period end date. For example, for a Q4 2012 report, the last day it could be created/ amended was on 12/31/2014.
Q. What amount do I report under the application amount – the initial amount on the application or the amount the application closes if it changes?
The initial amount on the application should be used when completing the Application data on the MCR. Starting April 1, 2015, a field has been included to capture changes in application amounts.
Q. What do I report as application amount if the loan was withdrawn or denied prior to the loan amount being known?
Even if no loan amount was applied for prior to the application being withdrawn or denied, if credit is sought, an application amount needs to be included. For MCR filing purposes $1,000 should be reported for the application amount when the application amount is unknown.
Q. What do we report under Net Changes in Application Amount (decreases should be reflected as a negative)? Application amounts may have changed from applications received previous quarters and Loans Closed and Funded reported under AC070 for the quarter are not always the same loans reported under Applications Received (AC020) in the quarter.
Here is an example of Net Changes in Application Amount flows within a single quarter or over two plus quarters:
For one loan:
Initial application amount (reported on AC020) when application is received: $100,000
Changes to the loan during the quarter (Q1) (report in AC065) - $ 20,000
Each application needs to be tracked and add all the changes for ALL loans into a net figure reported under AC065. If the loan application used in the example above, closes within the quarter, report that change to the loan amount in AC065.
If that loan application moves into the next quarter, it moves over at the lower net amount of $80,000. If another change to the application amount occurs during the following quarter, that change is reported the same way as in the above example for AC065.
Initial Application amount (reported on AC020) when application is received (Q1): $100,000
Changes to the loan during the quarter (Q1) (report in AC065) (Already done in Q1) - $ 20,000
Changes to the loan amount during the quarter (Q2) (report in AC065) $ 10,000
If the loan application in the example used above closes in Q2, report the change to the loan amount in AC065.
If that loan app moves into the next quarter, it moves over at the higher net amount of $90,000.
You need to continue tracking the loan amount until the loan closes.
Q. What do I include in the Broker Fee and Lender Fee fields of RMLA Section I?
Include all fees that your company has collected and retained. Examples include, but are not limited to, origination fees, application fees, and yield spread premiums (YSP). Do not include pass through fees. Note that compensation paid to MLOs is not considered a pass through fee.
Q. When reporting activity information on a RMLA component by state, is this based on the location of the property?
Yes, the activity information is based on the location of the property and reported by state.
Q. Does private money lending for any loan type on the MCR need to be included on the RMLA?
Yes. All residential mortgage loans must be accounted for on the RMLAs regardless of the source of funds.
Q. Does my company have to report loans on unimproved land or construction loans (other than construction-permanent loans) or other temporary financing on the MCR?
No. These types of transactions are not required to be reported at this time. As a reminder, construction-permanent loans MUST be reported.
Q. Our company does not collect fees directly from the borrower. Do I have to report fees I receive from someone other than the borrower?
Yes, you must report all fees received, other than pass through fees, regardless of whether they come from the borrower, lender or other party. At a minimum, these fees are reported in AC600, AC610, AC620 and AC630 as appropriate.
Q. I do not understand what Sections I, II, or III refer to in the RMLA section. Can you clarify?
Section I collects application, origination, line of credit, revenue and MLO information for the quarter by state. Section II collects more detailed origination information for the quarter by state. Section III collects servicing related information including modification and delinquency status for the quarter by state.
Q. How should I report loans in my company’s servicing portfolio that are in forbearance for COVID-19-related reasons, as provided for in the CARES Act?
Where the MCR asks for serviced loans to be reported by delinquency status, report loans according to their true past due date, regardless of whether the loan is in forbearance.
New Servicing and Qualified/Non-Qualified Mortgage Fields
Q. Is my company required to report interim servicing?
No. Interim servicing information under 90 days or collection of three payments or less is not reported on the MCR.
Q. If my company owns the servicing rights in states where we are not currently required to be licensed through NMLS, should we create state-specific RMLAs in those states to report the servicing activity so all reports balance, or do we report the additional volume under the "Loans Serviced - Nationwide Totals" section?
Your company has two options You can report the servicing activity in the nationwide totals section to reflect the additional servicing volume in those states where you are not required to hold a license through NMLS, but because this won't match up with the state specific servicing figures in the RMLAs, you will be required to acknowledge a completeness check warning and input a note for the regulators. The second option is to create new RMLAs for those states that you are not licensed in, input the servicing data for those respective states, and submit the filing. This approach will ensure that the nationwide servicing totals match the state specific servicing data, therefore there will be no completeness check warning to acknowledge.
Q. My company owns the servicing rights to all our loans but uses a subservicer to complete the servicing function. We have indicated in S540 Subservicing by Others, that all our serviced loans are subserviced by others. Do we need to report these serviced loans in S600-S1050 as well?
Yes. Your company should report serviced loans in S600-S1050 for loans that you have the servicing rights to. You need to report on all the loans you are responsible for servicing even if you have contracted with another company (subservicer) to complete that function.
Q. For some loans serviced, no pool numbers are assigned, but we receive an error message if pool number is left blank in Section III – Loans Serviced. How should complete these fields if no pool number is assigned to satisfy the Completeness Check error message?
Systematically filers are required to input a pool number, owner name, the UPB($) and Loan Count (#) in Section III – Loans Serviced if servicing information is provided. If no pool numbers were assigned, filers should use their own in-house pool numbers and retain proper work papers to provide the examiners during an examination.
Q. Are we required to report each individual pool, or should they be limited to investor type and provided in the aggregate?
Due to the large amount of data/pools that are being reported in some cases, pools should be limited to investor type and provided in the aggregate. Retention of work papers is important so that during an examination the pools can be reviewed adequately.
Q. As a subservicer, when entering Owner Name and NMLS ID # under S530 (Subservicing for Others), do we input the owner of the loan or the owner of the Mortgage Servicing Rights?
Report the owner of the Mortgage Servicing Rights.
Q. QM/Non-QM- We have loans in our portfolio that were originated before the QM rules went into effect. We have not and will not reclassify all of these loans into QM or Non-QM. How do I report those loans (that could be either QM or non-QM) in my assets?
Loans that were originated prior to QM regulation can be reported on line AC940 (Not Subject to QM) in the RMLA component of the Standard and Expanded MCR, and on line A060W3 (Not Subject to QM) in the FC component of the Expanded MCR.
Q. How should my company report a construction loan if it changes to a non-construction loan?
The construction loan will start as a non-QM loan, but once it changes over to a non-construction loan, it can be placed in the QM portfolio or category if it meets the requirements.
Lines of Credit
Q. How do we report warehouse lines of credit?
Currently, you must list your warehouse lines of credit on the company level information section of the MCR. The lines of credit should reflect all warehouse lines of credit the company holds and only that part which has been “committed.” “Uncommitted” amounts, funded at the discretion of the creditor, should not be reported.
Q. How do I report my MLOs on the MCR?
You must enter the NMLS ID of the MLO along with the dollar amount and count of the closed residential loans that MLO originated during the reporting period. If the MLO had no activity, you would enter zeroes in the amount and count fields but the MLO must be listed for each state they hold a license.
Q: Must the MLO information be entered manually?
No, the MLO information can be uploaded in conjunction with the XML upload or uploaded via a comma separated value (csv) upload file. For more information, please refer to the Mortgage Call Report XML Specification page on the Resource Center.
Q. What if my company had no MLOs during the reporting period?
If you did not conduct any activity during the reporting period then the MLO section can be left blank. If your company reported loan activity and you didn’t have any MLOs in that reporting period, then you should enter one of the control persons (MU2 persons) as the person conducting the activity with an explanatory note. For assistance, please contact the NMLS Call Center at 1-855-NMLS-123 (1-855-665-7123).
Q. What if we no longer employ a MLO but did in the reporting quarter - do we list them on the MCR?
Yes. You must list each MLO you employed during the reporting quarter in each state whether or not you employ the MLO when you submit the MCR filing.
Q: What does FAS stand for and where do I find this information?
FAS stands for Financial Accounting Standards and refers to specific guidance provided by the Financial Accounting Standards Board (FASB).
Q. Why am I receiving a data validation warning on the FC?
The text for the data validation warning in the system was updated to read:
The absolute value of D320 must equal the absolute value of C800 – C160 – D310.
The presence of a warning does not prevent submission of the MCR. If you encounter this warning message and have verified the information you entered is correct, you should enter this in the Explanatory Note Field:
We have reviewed the warning message related to D320 and have verified that the information submitted on this filing is accurate.
If all other completeness checks and warning messages are cleared, you will be able to mark the FC component as Ready to Submit.
Q. I have not filed my taxes yet and won’t complete them until April 15th. How can I complete the FC?
The deadline for the FC is 90 days from your fiscal year end. You must provide complete information in a timely manner to your state regulator. Failure to file on time will result in a deficiency placed on your company license.
Q. My company earns revenue from sources other than mortgage origination. I don't see a place to enter this information - what should I do?
All mortgage-related income should be reported. There are three specific categories for reporting mortgage-related income: 1. Origination Related; 2. Secondary Market Gains/Losses on Sale; and 3. Servicing Related. If the revenue doesn't fall into one of these categories, you should report it in field C770 (Other Non-Interest Income).
Q. If I don’t receive fees directly from the borrower, do I have to complete fields related to this topic (e.g. C210, C220, C230)?
The definitions do not limit this information to borrower received fees.
Q. I already submit the RMLA, why do I have to submit the FC?
The RMLA and FC are both components of the NMLS MCR requirement. The RMLA component provides information on loan activity and the FC provides information on the financial condition of your company.
Q. My company already submits a financial statement through NMLS. Why do I have to submit the FC?
The financial statement and financial condition component constitute different requirements. In the future, the system will accommodate a FC submission to satisfy a state’s unaudited financial statement requirement.
Q. We are unsure what to enter for non-corporate personnel compensation under Schedule D. Can you provide general clarification?
This section requires your company to report compensation expenses (salaries, etc.) paid to individuals serving in an origination, secondary marketing or warehousing capacity.
Q. Does the FC filing accept decimals or negative values in fields?
The system does not allow decimals and you should round the amounts to the nearest dollar. The system does accept negative values in the FC component.
Q. I am confused with C200. Do I report values for my mortgage business, my real estate business or my other businesses?
This section refers to originations-related non-interest income; and if your company uses fair value accounting for loans held for sale
Q. My company files consolidated financial statements either through the MBFRF or to state agencies. May we use these for the NMLS Mortgage Call Report?
No. The financial condition component of the NMLS MCR must be reflective of the licensee and its subsidiaries and not “rolled-up” or consolidated information of the parent company. The MCR-FC should follow the MCR instructions and generally accepted accounting principles (GAAP). Please be sure to report to the dollar and not in thousands.
Q. I just uploaded my independently prepared financial statement into NMLS. Do I also need to amend the FC section of the MCR?
If your independently prepared financial statement is materially different from what you filed on the MCR, then you should amend your previously filed MCR FC section so that it agrees.
Q. Will the MCR be made available to the public?
Company specific reports will not be made publicly available. Aggregate data may be released to the public at a future date.
Q. What happens to my data once it is submitted?
NMLS will process the data and release reports to state regulators on the submitted data. State regulators may also review individual company Mortgage Call Report filings within the system.
Q. Will the MCR replace all state annual or quarterly reports?
One goal of the NMLS Mortgage Call Report is to standardize and improve the information available about mortgage originations such that it can replace currently required state reporting. The decision is up to each state agency and many states have indicated that they will accept the NMLS Mortgage Call Report as satisfaction of their state specific reporting requirements. Contact your state regulator for complete information.