AARMR Encourages Consideration of Q1 2024 MCR Grace Period

On Thursday, Oct. 12, 2023, the Conference of State Bank Supervisors (CSBS) announced the Mortgage Call Report Form Version 6 (MCR FV6) will be released into production in March 2024. The changes in Form Version 6 (FV6) will allow state regulators to aggregate nationwide data on the entire mortgage industry and eliminate reporting outside of NMLS for companies that are not approved seller/servicers with the GSEs or Ginnie Mae.

Many of our licensees utilize information technology solutions, often provided by third-party vendors, to produce their call reports.  The changes in the new MCR FV6 will require IT updates by licensees and vendors. Industry will also need to identify the changes to requirements and plan to start collecting data in January to be prepared for Q1 2024 filing.  Although documentation outlining the changes for MCR FV6 has been posted on the NMLS Resource Center for several years, the technical specifications were not made available until mid-October of this year.

Given the tight time frame in which companies will need to adopt the changes, the American Association of Residential Mortgage Regulators (AARMR) encourages member agencies to offer a grace period for the Q1 2024 filing submission to the extent that your statutory and regulatory framework will allow.  AARMR also encourages member agencies to consider allowing licensees who have made good faith efforts to submit accurate Q1 2024 reports the opportunity to amend their reports, without penalty, if errors are subsequently discovered, to the extent that an agency has such discretion.

The update from annual to quarterly filing of the financial condition for over 3,000 mortgage companies that fall under new filing requirements will allow states to understand the sectors’ financial stability and mitigate risk identified by reviewing financial disclosures more frequently. This is increasingly important and beneficial given the current mortgage market.

The American Association of Residential Mortgage Regulators is a non-profit corporation whose mission is to promote the exchange of information and education concerning the licensing, supervision and regulation of the residential mortgage industry, to ensure the ability of state mortgage regulators to provide effective mortgage supervision for a safe and sound industry meeting the needs of the local financial markets and to protect the rights of consumers.