The FAQ is organized by the following categories:
Version 6 |
Industry-Specific (V6) |
General |
RMLA |
Servicing |
Financial Condition |
Company Level
Q. When will the Mortgage Call Report Form Version 6 (MCR FV6) changes go into effect?
Company users will be able to submit the Q1 MCR using the new MCR FV 6 starting April 1, 2024. Companies are required to collect and submit appropriate data for transactions on and after Jan. 1, 2024.
Q. What type of changes will be effective with MCR FV6?
Form Version 6 contains many changes. In sum, the changes create three main improvements:
- Eliminate standard/expanded forms and consolidate to one form; use business activities on the company form to drive zero-filling of irrelevant form sections and determine whether users submit an annual or quarterly financial condition.
- Eliminate commercial and consumer lending elements from mortgage reporting by creating a separate State-Specific Supplemental Form (SSSF).
- Edit line-item definitions based on feedback, bring more clarity to definitions and allow the implementation of more completeness checks.
Q.
Will MCR FV6 training be available?
In-person training for MCR FV6 was held during the 2024 NMLS Annual Conference & Training. In addition, live webinars were held on March 20 and 27. This interactive self-led course includes a demo of MCR FV6 functionality as well as both recordings for the MCR FV6 Webinar sessions held on 3/20 and 3/27. The Webinar recordings separated by date are stored in the last section of the course.
Q. When should I update my business activities to make sure my filing requirements are correct for the quarter?
The system will examine your company's business activities at both the start and end of the reporting period. This aims to generate a comprehensive overview of your company and identify the necessary data fields. It is crucial to maintain up-to-date records of your business activities throughout the reporting period to ensure accuracy in the generated snapshot. In addition, NMLS will automatically fill in irrelevant fields with zeros based on this information.
Q. What are open office hours and how can I join?
CSBS has designated staff available to assist with any inquiries regarding the upcoming implementation of MCR FV6. Office hours began Nov 6, 2023 and will end of May 20,2024. You can engage in direct discussions with a CSBS staff member every other Monday from 1 - 2 p.m. ET. During this time, CSBS staff will answer questions about timelines, changed or added report elements, and support resources available.
CSBS office hours are held via Zoom. Use the following link to join the office hours Zoom meeting (all sessions):
https://us02web.zoom.us/j/82102995323?pwd=dTV6WHdXWjZNUWVsQzVmVmpUdTR2UT09
Meeting ID: 821 0299 5323
Passcode: 102696
Q. Why is the MCR FV6 being implemented in 2024?
The MCR makes it possible for state agencies to compare data across states, aggregate nationwide data, and eliminate duplicative reporting outside of NMLS. The changes made in FV6 are meant to help advance these goals and will allow the state regulator to:
- Aggregate nationwide data on the entire mortgage industry for data points that were previously required only of Fannie/Freddie/Ginnie-affiliated lenders and servicers.
- These reporting requirements will also allow state agencies to eliminate reporting outside of NMLS for companies not approved by the GSEs or Ginnie Mae.
Q.
Will I now be required to file a quarterly financial condition (FC)?
The financial condition requirement will depend on the business activities of the company. Lenders and servicers will file quarterly financial conditions whereas companies whose record reflect broker-only business activities will file an annual financial condition.
Q.
How does a company's business activities influence my MCR filing in FV6?
NMLS will use business activities on the company form to drive zero-filling of irrelevant form sections. Review the
MCR Business Activity Mapping Table to identify the business activities associated with MCR FV6 sections.
Q. If my company reports brokering as its only business activity in some states, and lending or servicing in other states, what forms am I required to fill out?
Business activities are reported per state, the indication of filing as a broker, lender, or servicer is done at the company level. If a company conducts lending in one state and broker activities in another, the form required will be for a lender and broker. The company would be required to file a quarterly FC.
Q. What does zero-filled mean?
Sections on MCR FV6 that are considered irrelevant based on the company's business activities, for the reporting period, will be automatically populated with zeros, however, you can manually edit them if you need to.
Q. Where can specific questions regarding MCR FV6 be submitted?
If you have questions specific to MCR FV6, please email them to
MCRV6@csbs.org.
Q. Will the State-Specific Supplemental Form (SSSF) only be available if a state requires it?
Yes, the SSSF only displays as a component of the MCR form if a state requires it.
Q. What should my company include in the SSSF?
The SSSF is for states to collect data they were already collecting outside of NMLS. If your company is not already reporting the data outside of NMLS, it is unlikely that a state will require you to submit the SSSF.
Q. Which states will require the SSSF?
View a
list of state agencies that will require the SSSF.
Q. Do any state agencies offer a grace period or any leniency for MCR FV6 now that it is effective as of April 1, 2024?
View a list of state agencies that have provided information on offering a grace period for the Q1 2024 filing submission . If your agency is not listed, please contact them directly for guidance. This list also includes the state agencies that will require the SSSF.
MCR FV6 Questions From Industry Users
Q. What is considered a pre-qualification for MCR reporting?
A pre-qualification is an inquiry or informal request for information regarding a mortgage loan where the income and details about the consumer have not been verified with documentation. The only pre-qualifications that should be reported on the MCR are pre-qualifications that are considered an adverse action by The Equal Credit Opportunity Act.
Q. What do I report as the application amount for a shared appreciation loan?
Report the maximum cash advance amount.
Q. Which loans should be included in I330 and I331?
I330 and I331 should sum to equal I100, the total residential mortgage loans closed in the Residential Mortgage Loan Activity (RMLA).
Q. What should I include in AC063?
AC063 is meant to cover situations that do not fall into the other normal pipeline categories. These situations should be unique and rare, hence the requirement for explanation. One example is an application that changes between neighboring states. A normal entry here would be zeroes.
Q. What is the difference between AC063 and AC065?
Use AC065 to report changes in application amount for loans that stay within the current state's application pipeline. AC063 should only be used in instances where an application is removed from or added to the state's application pipeline during the reporting period.
Q. Are pre-approvals still required for reporting, given that they are no longer mentioned in the definition of an application and all dedicated pre-approval fields have been removed?
Refer to the definition of “Pre-approval" in the definitions and instructions. Bonafide pre-approval requests would be reported the same as any other application. If you are referencing pre-qualifications, these must be reported only if a denial of credit has been made.
Q. If my company indicates lending business activities at the beginning of the reporting period but changes to only broker activities before the end of the quarter, how does this impact my MCR?
If a company is engaged in lending at the start of the reporting period, the lender data fields would need to be completed as lending activities were indicated during the reporting period. The system checks your business activities at the beginning and end of the reporting period, filling in zeros for irrelevant fields based on these activities.
Q. If my XML upload file has data populated for sections that would be prefilled with zeros based on my business activities, will the system still let it go through or will it cause an error?
If the XML file meets the schema, the system will populate the data provided into the fields indicated. If you are not required to complete the section or certain fields but you provided data, then you can either change these fields to zero or you can submit the report with the data but would have to ensure all completeness checks pass.
Q. What if my company is licensed in a state or has licensed mortgage loan originators (MLOs) 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 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. If my institution is only federally registered on NMLS and we only employ federally registered MLOs, are we required to 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. 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. My company operates in multiple states. Do I file a MCR for each state?
Only one NMLS Mortgage Call Report is filed per company per quarter. This one report includes a separate breakout for each state in which the company is licensed or has licensed MLOs. This allows you to report the activity you conduct in each state separately.
Q. Does my company have a limited time 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 2022 report, the last day it could be created/ amended was on 12/31/2024.
Q. Will the MCR be made available to the public?
Company specific reports will not be made publicly available by NMLS. NMLS may aggregate data and release aggregated data to the public at a future date. State regulators may be subject to state public records law requirements to make the state's MCR information available to the public in certain circumstances.
Q. Will the MCR replace all state annual or quarterly reports?
One goal of the MCR 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 MCR as satisfaction of their state specific reporting requirements. Contact your state regulator for complete information.
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. If the application amount changes prior to closing, use field AC065 to capture those changes.
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.
For example:
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. Does MLO information be entered manually?
No, MLO information can be uploaded in conjunction with the XML upload or uploaded via a CSV upload file. For more information, please refer to the MCR User Guide.
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.
Q. What if we no longer employ an MLO but did in the reporting quarter − do we list them on the MCR?
Yes, you must list each MLO you employed that closed loans during the reporting quarter in each state whether or not you employ the MLO when you submit the MCR filing.
Q. We have loans in our portfolio that were originated before the QM rules went into effect. 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 financial condition 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.
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. Retaining work papers is important so that pools can be reviewed adequately during an examination.
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. 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. I have not filed my taxes yet and won't complete them until April 15. How can I complete the Financial Condition (FC)?
The FC is meant to capture unaudited information about the company and if there are material differences after taxes are completed or you have audited financial statements, then you should amend your FC and provide the corrected information. You must provide complete information in a timely manner to your state regulator and 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. 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 (e.g., 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 MCR?
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. How do we report warehouse lines of credit?
Warehouse lines of credit are provided in the Company-Level Information component. 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.