RD427 - Report on the 2025 Operations of the State Regulatory Registry LLC and the Nationwide Multistate Licensing System and Registry


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:

1. Annually review the proposed budget, fees, and audited financial statements of the Registry;[1]

2. Annually, to the extent practicable, report to the House Committee on Labor and Commerce and the Senate Committee on Commerce and Labor on the operations of the Registry, including compliance with its established protocols for securing and safeguarding personal information in the Registry;

3. To 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 demo-graphic information to be prepared by the Registry or its test administrator; and

4. Report violations of this chapter, any enforcement actions thereunder, and other relevant information to the Registry on a regular basis.

On behalf of the Commission, its Bureau of Financial Institutions (“Bureau") is pleased to submit this report on the 2025 operations of the State Regulatory Registry LLC (“SRR") and the Nationwide Multistate Licensing System and Registry (“NMLS").

SRR was formed in 2006 and is a non-profit corporation based in Washington, D.C. It is wholly owned by 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 is directed by an eight-member board of man-agers consisting of state regulators. SRR owns and operates NMLS on behalf of state financial services regulatory agencies and carries out mortgage loan originator (“MLO") testing and education requirements under Title V of the Housing and Economic Recovery Act of 2008 – specifically, the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (“SAFE Act").

NMLS was initiated by state mortgage regulators in 2008 in response to the increased volume and variety of residential MLOs. 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.

Through NMLS, SRR supports the strategic goals of the CSBS members, assisting state agencies in consumer protection and supervision of non-depository financial service industries by providing technological resources and information on a nationwide basis.

State regulators are the primary licensing authority for non-depository financial services companies. Non-depository financial services companies include, but are not limited to, mortgage providers, money services businesses and consumer finance companies. State licensing of MLOs is maintained through NMLS as is the registration of MLOs employed by state or federal depository institutions. In 2025:

• the Bureau received 5,850 MLO applications (compared with 5,063 in 2024); and

• the Bureau’s Commissioner of Financial Institutions approved 5,286 MLO licenses (compared with 4,463 in 2024).

SRR has established protocols for securing and safeguarding personal information and conducts cybersecurity risk audits annually. SRR did not experience any material issues related to NMLS security and privacy of information in 2025.
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(*1) Code § 6.2-1700 defines “Nationwide Multistate Licensing System and Registry" or “Registry" as “a mortgage licensing system developed and maintained by the Conference of State Bank Supervisors and the American Association of Residential Mortgage Regulators for the licensing and registration of mortgage loan originators."