RD246 - Report on the Operations of State Regulatory Registry LLC – June 22, 2021

Executive Summary:

This Report was prepared pursuant to Title 6.2, Chapter 17, § 6.2-1720 D of the Code of Virginia ("Code"), which directs the State Corporation Commission ("Commission") to:

• annually review the proposed budget, fees, and audited financial statements of the State Regulatory Registry LLC ("SRR");

• annually, to the extent practicable, report to the House and Senate Committees on Commerce and Labor on the operations of SRR, including compliance with its established protocols for securing and safeguarding personal information in SRR;

• the extent practicable, prepare, publicly announce and publish a report by no later than July 1 of each year that summarizes statistical test results and demographic information to be prepared by SRR or its test administrator; and

• report violations of this chapter, any enforcement actions thereunder, and other relevant information to SRR on a regular basis.

On behalf of the Commission, its Bureau of Financial Institutions ("Bureau") is pleased to submit this report on the 2020 operations of SRR and the Nationwide Multistate Licensing System and Registry ("NMLS").

SRR is a non-profit subsidiary of the Conference of State Bank Supervisors ("CSBS"), a national organization which advances the quality and effectiveness of regulation and supervision of state banking and financial services. SRR operates the NMLS on behalf of state financial services regulatory agencies and carries out mortgage loan originator ("MLO") testing and education requirements under the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 ("SAFE Act"). Through NMLS, SRR supports the strategic goals of CSBS' members by assisting state agencies in consumer protections and supervision of non-depository financial service industries by providing technological resources and information on a nationwide basis. NMLS is the system of record for non-depository financial services licensing or registration, including the licensure of mortgage companies, in participating state agencies, the District of Columbia, and the U.S. territories of Puerto Rico, Virgin Islands, and Guam.

The impact of COVID-19 coupled with a dramatic surge in test administrations presented a unique set of challenges in 2020 for SRR. In March, all testing centers were closed abruptly, and all test administrations halted. SRR's testing and education staff worked with its testing vendors and its approved course providers to quickly find solutions to these unusual conditions. During 2020, over 67,000 MLO test components were administered by SRR. At the end of 2020, NMLS was the licensing system of record for 64 state and territorial agencies, managing a total of 508 different license authorities covering a broad range of non-depository financial services. In 2020, 8,428 individuals applied to be licensed as MLOs in the Commonwealth after taking and passing the National Multistate Licensing System Loan Officer exam ("National Test") and 7,004 of those individuals were approved for licensure.

As of December 31, 2020, SRR reported audited total assets of $190.4 million and net income of $11.9 million. The certified public accounting firm of RSM US LLP issued a "Clean" or Unqualified Opinion of SRR, and the financial statements and budgets appear to be accurate and reasonable. The Bureau does not take issue with the disclosures therein.

In addition, SRR did not experience any material issues related to NMLS security, privacy, or information breach in 2020, nor was it subject to any significant litigation in 2020.