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# Life After Approval - Post-License Maintenance

> This webinar covers what license holders are responsible for after approval, from renewals and NMLS filings to reporting material business changes and clearing regulatory deficiencies. It is aimed at teams that keep licenses in good standing across multiple states, and it focuses on the calendars, documents, and internal habits that make that upkeep manageable.

Recorded: 2026-08-17 | Runtime: 58 min

## Key takeaways

- License holders typically must submit renewals to keep licenses in good standing, as perpetual licenses are becoming less common.
- States may require license annual reports, which are distinct from Secretary of State annual filings and often focus on financial data or bond calculations.
- Material changes such as updates to ownership, officers, or business addresses often require reporting to regulators, frequently within 30 days of the occurrence.
- Many regulators require proactive and consistent communication regarding deficiencies, as they may not receive automated notifications when items are uploaded to the NMLS portal.
- Developing a reliable internal data management system helps track due dates and maintain continuity in reporting across multiple jurisdictions.
- Submission timelines for renewals are often first come, first serve, making early filing advantageous to avoid end-of-year backlogs and technical issues.

## Transcript

Hey everybody, good morning, good afternoon, wherever you are. my name is Joel Blackburn. I'm senior account executive here at Cornerstone Licensing and we are thrilled to have you join us today for this timely webinar. today's topic is life after approval postlicens maintenance. Getting licensed, as many of you have probably found, is a major accomplishment. But approval is only the beginning. From that point forward, your business enters a new stage, ongoing license maintenance. Staying in good standing requires awareness, organization, and proactive management. So, in this webinar, we're going to look at life after approval, including what regulators expect from license holders year after year, how renewals, amendments, reporting requirements fit together, and many other facets of the license maintenance process.

our hope really for today is that you're going to walk away with clear tools for how to manage licensing to not feel quite as overwhelmed because we're, you know, approaching a season where there are a lot of renewals coming up and just kind of give you as many tools as possible to equip you. I have been particularly excited about this one because for a lot of our webinars that we have, we're we're all in separate locations. We've got people, you know, experts in the various industries that we work in who are joining us from all over the country. today we get to have it all here in house and I we're sitting in our training room here in Alpharetta, Georgia.

And I am pleased to be joined by Dawn Graham and Jennifer Kim who work tirelessly with our renewal licensing department to really make this whole thing run. And many of you I see we've got a lot of clients on the call today. Many of you already know Dawn and Jen. So you get to hear from them a little bit more today, a little bit to glean from their expertise. Dawn is our training and development manager. she is she's leveraging a decade with corner decade. Yes. [clears throat] Yes. Good grief. Yes. I know, right? she's she also had a career in education prior to Cornerstone. So she uses all of her experience to design scalable step-by-step training programs.

She equips our licensing specialists in this very room to master complex state-by-state requirements and accelerating ramp time and elevating quality. I've seen that firsthand. Thank you. Jennifer Kim to my right is our renewal department manager and she leads our renewal team and she orchestrates a nationwide portfolio with standardized workflows and proactive tracking to keep filings current and on time. And you're in your sixth year at Cornerstone. Six years. Gosh, I feel like you've been here a decade, too. Me, too. [gasps] She manages our renewals team and drives accuracy, predictability, and measurable turnaround improvements. due to the nature of the topics we'll be discussing today, we need to establish the following disclaimer.

This information is not intended to be legal advice and may not be used as legal advice. Legal advice must be tailored to the specific circumstances of each case. Every effort has been made to asssure this information is up to date. It is not intended to be a full and exhaustive explanation of the law in any area, however, nor should it be used to replace the advice of your own legal counsel. you are invited to submit questions in the Q&A as we go. we really welcome them and we hope to be able to have time to go over some of them you know during and at the end depending on how much time we have.

But I don't want to hold up these ladies any longer. So I really want to get into the meat and potatoes of what we're discussing today. So we are you know approaching the end of the year when we've got a lot of renewals coming up. getting down to crunch time, getting down to blood, sweat, and tears time here at Cornerstone. so but let's back up and just kind of establish the ground rules here. So why isn't getting licensed the end of the road? Like what, you know, because I think I talked to folks who think, okay, I've got my license, I'm good. Why is that not the full story?

well, I guess quite frankly, in most cases, it's because the license itself is only going to be valid for a certain term. And so that license is going to in fact expire. There are just a few states that will allow you once you get licensed, that license is in place. It's really nothing else to do. We call that a perpetual license, right? But in the majority of cases, the states are going to require you to submit a renewal in order to keep that license in good standing. So that's basically the long and short as to why once you get the license, that's not the end of the road.

Okay. Okay. is it so it's relatively uncommon then for a for a license to be perpetual? Correct. And you know this is all based on the states and their requirements. So there are just a few states that say hey once you go ahead and get your license you're good to go. We don't need to bother you. Don't bother us. But the majority of states will say no. In order for us to make sure that you are in compliance, you're going to have to submit paperwork or an online filing or whatever it is that they require for you to keep that license in good standing. Gotcha.

And you know, to add to that, you know, there are states, you know, that were perpetual and then sometimes they changed their mind and they're like, now you have the license. You know, good example is California recently. Yeah. No, in 2020 they just decided that all collection agencies and you know finance law agencies have to you know now license to collect and so that just created a whole storm where you know everybody was trying to you know scatter and you know get their license and so that any state can change at any time. Sure. And so and then there are states that can also withdraw their requirements to say no we don't you know require a collection agency collection agency.

So, yeah, always changing. That's true. And while we're talking about the changing nature of these, a lot of states are also changing to they're transitioning into NMLS. Can you just explain real quick what NMLS is and why it's relevant for this conversation? So, the way I like to look at NMLS, the nationwide mortgage licensing and now multi-state, not just excuse me. Yes. multi-state is I consider it like a holding place, right? So, a lot of people think it's NMLS requirement and NMLS requirement. No, it's still actually the state's requirement. It's just that state is allowing for NMLS to be like the governing system by which you would submit forms, documents, and renewals, you know.

with it going into NMLS, I think a lot of I remember when I came on in 2013. I think NMLS was brand new to the collection agency licensing world. I think it may have started at the end of or the beginning of 2013, the end of 2012, something like that. But in either case, it was still relatively new to us and it was kind of intimidating. I remember, you know, coming in new to the specialist role at that time. Yeah. But now with all of the advancements and the changes and the things that have made in the system, it really does make governing your licenses that much easier.

So a lot of states have said, you know what, the maintenance for websites for all that is involved with that, it's just not worth it to them. and they're saying, "Hey, if we can go ahead and allow this to transition into NMLS, we still have access to all the information that we need and require. Why not do it?" And so, I think more and more states are coming on board and transitioning their licenses into that system. That's right. And around that same time, we started seeing not, you know, because it started as a mortgage platform like you alluded to, but we've seen, you know, lender licenses, money transmitter licenses, collection agency licenses.

it's really becoming more and more all in all-encompassing for the financial services ecosystem. So, but so one of the common things we hear from people coming in the door here is like I started my NMLS profile, I started my renewal, I started my whatever it may be within NMLS and I hit a wall. what kind of what kind of guidance would you give to people who are running into that sort of you know issue in terms of like what are some common things you see some common roadblocks within an MLS that are this making it hard for people to either get their profile set up or renew you know an MLS is it does like Don said offer you know vast amount of information there and so because of that it's just navigating it can be very tricky.

that's why Don does a great job in training you know her specialists to get you know accustomed to it. I would take you know I would say that you need just at least a few months training just to be adequately equipped to do filings in there find what you want in the right places. I think that you know sometimes you know people who you know don't have may maybe the guidance of you know you know third party companies or don't have like a you know licensing team that just focuses on NMLS they can miss out on the things like deficiencies that are listed on licenses you know where to you know load the deficiencies you know where to put you know how to label your financials you know so down to the label down to like the file name Exactly.

Because if you put your financials as a year to date instead of like an annual financial, they're not going to get the state is not going to get the correct, you know, financials where they're going to say it's labeled wrong and create another deficiency. And so there's a lot of those, you know, idiosyncrasies that are hard for, you know, people who are not accustomed to navigating that space. So, so in terms of NMLS, and this is good because so many of our clients across the industries that we work with have licenses in NMLS. How do you deal with those deficiencies? How do you what and what effect are these deficiencies going to have on a license renewal?

Specifically, like looking ahead at like 1231, if I still have a deficiency as of January 1 of 26, what does that mean? So, well, I want to come back to something else before I forget about it. in terms of the idiosyncrasies when it comes to NMLS and some of the mistakes that we see are commonly made and that roadblock that can come up. It's just sometimes it comes down to just the verbiage with NLS. You know, they refer to a company filing as an MU1. And then you have terms like MU2 and MU4. And people get really confused. I found a lot of times with those two distinctions.

And just understanding MU2, yes, is a person. MU4 refers to a licensed individual. And so sometimes people get in and they're like, "Oh, I need to submit this for me." And they do an MU4 filing thinking because they're a person that's what they need to do. but in fact, no, you're going to do it through an MU2 filing for the company. So, those kind of things can trip people up. it's funny coming from education, when it comes to the deficiencies, I look at it a little differently, right? In my era, and I'm a little older than everybody here, but in my era, there is no such thing as like the types of study guides that my kids get, right?

they get study guides to tell them pretty much exactly what's going to be on the test and that's how they know to study and so forth. I kind of look at deficiencies in that same vein. If you get a deficiency from a state, it's really not the end of the world. The state is telling you this is what we need. And so if you give them what they are outlining in that deficiency, you can pretty much move forward without you know circumstance. And sometimes there are those imaginary drop down windows, right? where you give them one thing and now they ask you for something else.

But still, if the state is in communication with you saying that these are the things that we're going to need you to address in order to clear this license item, I look at deficiencies as a get out of jail free card. Like just this is what you're asking me for. Let me give you that and then we can proceed. It's actually a moment of clarification. Absolutely. instead of, you know, just leaving them to figure out whatever the problem is on their own. It's the regulator actually stepping in and saying, "Here's the problem. This is Z. Fix it." Yep. Had not thought of it that way.

It's cool. so NLS, it could involve NLS licenses or not, but what are some common missteps or surprises that newly licensed companies might encounter in their first year? It's like, okay, I understand that I need to renew, but oh, I didn't know this was part of it. Yeah, that's that's part of it. They don't know what's part of it. Like a lot of times when you're talking about licenses, you're talking about license annual reports, right? A lot of a lot of states have that as a requirement there. You're talking about financial statements that are due, but with those annual reports, you're not talking about ju you're not talking about Secretary of State annual reports.

talking about license annual. Absolutely. And a lot of times that has tripped up, you know, our clients who are like, "Wait a minute. I just got this license. Why do I have to?" Well, unfortunately, you have to because the state is saying you have to. And so, and even if there's nothing to report, you're still going to have to complete the report indicating that there was no collection activity or whatever type of license that you hold and you still have to get that submitted. I think a lot of times clients get confused, don't understand that just because you've only been in business in this state for the last three months does not mean you are exempt from submitting this particular file.

Sure. And I think to add to Don, I think an important for my the clients that I [clears throat] have that are su successful in you know clearing deficiencies and make sure they're communicating with the state on time is having like a designated company email address where all those you know all those deficiencies all those emails from regulators go because when there is you know two emails that are going to officers they might get busy if it's going to like a you know a manager they can skip over it. So, I think especially my burger companies, they have a designated like licensing act, you know, and so they have somebody constantly monitoring that email address.

So, anything that comes through, they can make sure that they're, you know, responding to that in a timely way. So, but I mean, even for you're you're referencing the biggest guys, but like in terms of like even smaller companies, they could also benefit from having a single repository as it were where all of those are going to go. I mean is that a good idea even for smaller companies? I definitely think so. you mean I recently had a smaller company they got you know you know licensed for a mortgage license and they had put that general email you know box and they were able to look through there and make sure that you know that report that was due with that mortgage license was going to be due in two months.

they didn't have any activity, but it clearly said it clearly said, you know, you have to send in this report regardless of, you know, if you had any activity or not, you know, and so I think it's very important that they have some kind of designated email. That's so good. I'm learning a lot here today, too. so can you share an example of a client who maybe nearly lost their license due to a postapproval compliance issue? Like it came up on renewal time and something happened or something didn't happen. and maybe talk through like what could trigger that kind of, you know, death nail where a license is actually lost.

Like, you know, like you said, you know, the end of year is coming. Wyoming in particular comes to mind. They used to be I don't know if they still will be this year. We just never know. in years past they have been pretty strict about the renewal items that come through and if something is you know wrong because there's you know a lot of forms that go with it. so if you do have a deficient item they used to give us maybe was it seven days and then they lost their license if it wasn't approved. So us as, you know, specialists, I remember us making a special effort to put those u reminders on us every couple days so that we're constantly checking, you know, to make sure that, you know, nothing comes in and that we get that addressed, you know, in a timely manner.

Last year, they gave fines, hefty fines for that, but they didn't yank licenses, but in the years past, and we never know this year what they're going to do. Sure. You know, so the fines are pretty common then for I mean, what dollar amounts are we talking about? just it's it's hard to say because we're talking about a lot a vast amount of license types, but yeah, there are some states that will give you a per day f fee for every day that you are late in submitting the filing. And that I've seen that range from like $10 to $25 a day. And so depending on how long you allow that, you know, to go and then there are others that if you've missed a day, they have a set dollar amount for their fine.

And you know, we have reinstatement fees and things of that nature. And so those can vary from state to state. Okay. Okay. so let's talk through some of the common things because we've got renewal season upon us and you know maybe this is the first renewal season for somebody who's listening right now. what are some common requirements to expect and maybe what are some less common requirements that might be you know to be expected you know. Let's talk through, you know, some of the things for like, you know, money transmitters, for collection agencies, for lenders, whatever. I'll let you take the direction you want. Okay.

Well, I'll start with the common things. All right. There are many common things that you're going to have to supply with these renewals. So, it could be like a certificate of good standing. You'll need to get that for certain states, both for the state that you're licensed in and then also for your doicile states. You may have to provide those. you may have to provide certain states with your list of collectors or if you're using an alias, there may be a form that you have to give them for that, you know. you may have to submit criminal background checks and NMLS and for renewals, not just for the initial license, but also for renewal.

Correct. Correct. And even if you have done your prints, you know, they haven't expired, they're still going to collect the funds necessary for them to run those through the system. So, fingerprint hasn't changed. It has not changed. Your fingerprints are exactly the same. However common you're going to pay $37.15 or each and every MU2, you know, for state of Massachusetts. So, it's just, you know, it those are some of some of the common ones kind of off the top of my head that, you know, you can see from time to time to come up with these renewals. And then some of the uncommon ones, Jen, you want to Yeah.

So, some common ones I've seen are police reports on, you know, certain individuals. Those are not the same as a background check. Yep. So, certain licenses only have one applicant or it could be the owner, the officer, and then they require the police reports on them. I also have seen personal references. They want personal references. they also like with money transmitters, I've seen permissible investments that they need to report those. and also like things like cyber security, they want, you know, their policies, eno policies, you know, copies to make sure that they're up to date. Those are some less common, but definitely out there. Sure.

Sure. so what's our are we looking at annual timelines in general or are we looking at like every two years? Is I mean it's all throughout the year, right? I mean, what's our what's the general rhythm? Is it annual? I would say that most renewals are annual. maybe like let's say 90%. Yeah, I think that's a fair number. 90%. And most of them come the end of the year. there are a bit a heavy number that are also due mid year in June. but then there al also ones that are due from the anniversary date of when they were licensed. Okay. Okay. So it's just I would say it's sprinkled throughout the year.

Yeah. But heavy on the you know mid and end part of year and more and more with more licenses going to NLS and we've seen a lot transition over too. Yes. It seems like there's a few new ones every year and NLS is pretty good about sending out updates when they are going to have one of those transition periods. But then but then the bonds if the license requires a bond that bond might not renew on the same cycle as the license. So, correct. That might be an additional thing to have to keep track of. Yeah, those are always fun, aren't they? When the bond has its own term that's not the same as the license renewal.

Yeah, those are those are joyful. Yes, joyful is one word. so in terms of this, this could be a webinar in and of itself. Let's talk real quick about what types of changes in business structure could create an issue come renewal season. Oh, well, you know what? They could become an issue renewal season or at any point in time. Actually, I probably framed that incorrectly because if you're waiting till renewal season to report it, yes, you're you're in trouble. So, let's talk about just like during the year like I've got a new officer. I had an officer leave. Mhm. We're changing from an ink to an LLC.

Talk to me about that. Yeah. I didn't even think about the whole conversion process that you're alluding to if you're changing like the actual business type, but that is definitely a change item. We refer to these as material changes. And so, anything like your address changes. And let me be clear, we are currently at 925 North Point Parkway, right? Sweet 470. If in fact Cornerstone decides to move to the second floor, we go to suite 270. That is in fact an address change and that does have to be reported to the states. you have officers where we have Jeff as our CEO and now we want to hire on a CFO and that's been reported to the states or something's been changed or whatever.

An officer change that is a material change an ownership change that is a material change what could which could excuse me in fact lend itself to a rellic depending on what those state statutes say. So, I feel like oh an excuse me, a manager if in fact you need to bring on a backup manager or if your manager is leaving or whatever the case may be. All of those things have to be reported to the states. The majority of states want these things reported within 30 days of occurrence. There are some states that want to know about these things prior to them taking place. And so there's a lot involved.

Sometimes when certain states have requirements, we're talking about bonds, right? Well, if your business has exploded and the bond is dependent on how much business you are actually generating, then you may have to report that as well and get a you know a writer to your bond. So, there are quite a few items that can take place which will require you to do additional reporting to the state. What kind of penalties are you looking at if one of these changes is not reported in a timely fashion? So, depending on the states, it really and I hate to sound so vague, but I want to keep it vague, you know, just so you understand.

It can go anywhere from a slap on the wrist where, hey, you didn't tell us this in enough time. Make sure you don't let that happen again to a hey, you need to stop collecting until you get this generated. Especially in the cases where you have a manager and the manager leaves and that manager is connected to the collection agency license requirement or any other type of license that requires you to have a state manager in place. It can you can get fined. excuse me. You're going to get a discipline disciplinary action on your license. And be advised, if you get these disciplinary actions on your license, guess what?

Many states are going to ask you, do you have any current disciplinary actions on your license from whatever state and you have to disclose that? So there are many different penalties and actions that can you know come about because these changes have not been reported and they can come up within examinations as well. there's a lot of states recently that have done examinations and they have asked you know we saw that you changed your officer in this year please tell us where you recorded it please tell you know and all that paperwork that you sent in and I don't know what has happened I think has been like you know a range of those things depending on the state but they definitely do catch those in examinations as well.

So what go ahead. Oh no, I was just going to say as well to that point in attending the NMLS conference earlier in the year, one of the things that was discussed was that the regulators do often communicate one with another. And so one of the benefits and possible drawbacks to being in NMLS is that the information is accessible to all of the regulators in the system. So we always try to emphasize consistency in reporting and making sure that what we are reporting is up to date for each and every licensed jurisdiction that our clients have. So I was just going to ask either of you if there is somebody listening today who's hearing us talk about you know changes and they're like oh that's me.

This happened in 2023. like no there's no shaming here. but what kind of advice would you give on the best way to handle it? Quickly would be my best advice. you want to what's done is done, right? And we've been in those situations. I know Jennifer, I'm sure, has had to deal with that. We, you know, have seen it through the years. What's done is done. The best thing to do is to move forward with the accurate information as quickly as possible. If you in fact know that, wait a minute. Oh, we did submit that last annual report. I noticed that Joel's name was on it, but I didn't think anything about it.

Well, no, you do need to go ahead and update it as it needs to be updated to every state that you currently are either registered or licensed in. Yeah. the so the regulators I my guess is that the regulators are going to respond much more kindly to a proactive reporting of it versus a hey we discovered this from this document that you didn't mean to disclose it in or whatever means it might be they would rather have the proactive versus the hey we caught you yeah is you know I know us sitting at the table are all parents right and we much rather our children come to us fess up than we catch them, right?

And so the same thing can be said, you know, and I mean oftent times and we know how this goes. Different companies contact people change, compliance managers change, information can sometimes slip through the cracks. And so you keep in mind that the we call it the states, right? But the people in position are in fact people. And so, you know, mistakes can happen, problems occur. Just being honest and forthright as best you can usually will save you, as best they can, you know, with dealing and rectifying a situation. Yeah. Yeah, it's good. transitioning to a happier topic. in terms of annual reports, we've differentiated between there's the Secretary of State annual reports and then the, the license annual reports in many cases.

what do the regulators typic typically expect on that? is that I assume there's a volume component of it. what's the difference of you know reporting requirements between the secretary of state ones and the state license the license and reports. Yeah. So with secretary of state usually they just want to make sure that you're maintaining that the address is correct, your registered agent is correct owners and officers of those sorts. Sometimes they ask disclosure questions about the officers but mostly just maintaining just the accuracy of all of the company information to keep that company current and able to transact business in that state. Sure. with the license and reports that go with the you know each license they're more heavy in terms of they want to know things about their financials.

Sometimes we have to submit financials to them. also there's different things about bond calculations, how much the bond needs to be according to the volume of activity. Yeah. sometimes there are disclosure questions but mostly I would say it's very financial and bond heavy as far as the licensing report that we've seen come through. Sure. Sure. Okay. with the I know we've got a wide array of companies at Cornerstone from like a single license to hundreds of licenses. how do you recommend businesses track and manage these due dates across multiple licenses because it can get a little overwhelming, can it not? Yeah. my best advice is to have a very good data management system in place.

It's really going to save you because again, it can seem a little daunting when you're dealing with so many licenses, but as we were talking about earlier, a lot of these licenses have common requirements. And so, it gets to be a little, oh, okay, we've had to do it may look a little different, but we still had to do a financial form for that state. So we're familiar with what it is that this state is asking us for, right? But in terms of keeping track of everything, I know once upon a time there was no data management system here. At least that's what I was told 20 some odd years ago.

I don't know how they did it. All of us. Oh my gosh. Yeah. Yeah. Definitely right. That was in the boxes in the file cabinet things. But we have a tremendous system. Shameless plug. We have a tremendous system for keeping track of our clients licenses, due dates, and things of that nature. So, I would if I'm giving advice, that would be my advice to make sure that you have a very good data management system in place. And we've we've seen some pretty elaborate spreadsheets over the years. I could say like I've seen some Excel spreadsheets and I'm like, I didn't know Excel did that. But I've got a screenshot of our Atlas portal up right now just so that people can kind of see what it looks like and how it kind of it helps you keep track of all of it.

But I do want to stress like that is for that's a tool for our clients, but it's not up to them to manage the license. This is just a transparent way for them to see, download, communicate. but you know, this is it just gives you a peak kind of behind the scenes as to what cornerstone what the specialist is working on. But I think I think you're spot on. Like the data management system is so crucial because we talk to all shapes and sizes and we talk to companies that are like, I thought I could do this and now I'm in trouble because I see that I can't and they either got the slap on the wrist or they feel like they're about to.

And I mean, what is there any different advice you'd give to a company that's got like five licenses versus like 50 licenses? Like is there a difference in the way that you manage that type of workload? I'm gonna let you do that one, Jennifer. Well, [clears throat] so I think when Don was like saying the data management, she didn't necessarily mean that the, you know, company go and make their own software need, you know, like our software, otherwise they wouldn't need us. right. So, but I think successful clients of mine who have you know, they've saved renewals that they have filed from last year, the previous year, they use that as a reference and that really helps them because again, these license renewals come yearly.

You could forget a lot in 365 days. So, and sometimes every two years and so I found that you know the those clients who have those systems in place where they do have you know archives of whether it be electronic or whether it be just a paper you know like you know file folders they are quicker to get those you know forms back to get those renewals submitted because they have something to reference from the previous year. of course the first year is going to be, you know, harder. but again, you know, here at Cornerstone, we will, you know, help you through that and, you know, yeah, things like that, but definitely to have some kind of organization.

and, you know, I think that would definitely help as far as managing those licenses. Sometimes with five licenses, it could be just as hard as a client that has 50 licenses. Because it depends on what those licenses are, Yeah. that is a big thing and also just how organized the client is too. and it doesn't even necessarily ma matter how many people are on their you know team either. It could be one person but as long as that person has kind of like an kind of a rhythm and flow of how they you know get back to us or you know however they submit then I think that definitely helps.

M it's good cuz I mean the regulator has access to previous years filings. So it would make sense for the for the license C to also have access to those because I'm guessing that you could get in trouble if like say you forgot what you filed in 2024 and then you file something in 2025 that doesn't sync up or it contradicts what was filed before. so I'm guessing some continuity there is pretty important and some consistency between reporting for sure. Okay. Okay, cool. just a reminder if anybody's got questions like please feel free to ask. We are we'll do Oh, I do see one here.

that's a good question. Do you have do you all have an official training class or seminar for licensing and secretary of state? we do not. but I think that's a fantastic title for a coming webinar. So stay tuned for that. cool. So keeping moving here. we've already kind of talked about the consequences of missing a renewal, but like I think a lot of companies on here are maybe thinking about new either new business models to move into, new states to move into. but what do you wish companies knew before they received that approval? Like what how would you how would you counsel somebody if they were like say you know I've never I want to go into California for instance like what do you what how would you counsel them on like okay you can do that here's what to expect.

and that could be before or after approval. I would say the main thing with this is that they need to be patient because these regulators move on their own divine and no matter whether a pro a license is submitted by paper or by on you know online means which you would think that would be faster that's not necessarily the case and also to expect that you are going to get a deficiency because it hardly ever the first time submitted it will be approved. But wait I hired cornerstone why am I getting a deficiency because sometimes we cannot predict what you know these regulators want so if let's say for a disclosure question you know like they ask you know a certain question pose a certain question about has this person ever you know you know been involved in this and we say yes and we you give the you know regulator the explanation or proof whatever proof then they could come back and be like well we need a little bit more, you know, that's not going to be satisfactory and we need this, this,

and this, which wasn't on the original application, but because they dug further into it, they've deemed it, you know, necessary to ask for more. So, there are a lot of scenarios like that. Yeah. which come which comes up sometimes they we submit financials and they're like, well, we have a question about the net worth. We have a question about why, you know, this is showing as this. Please, you know, give an explanation about, you know, what you would do to make sure this net worth goes up. And so all these scenarios where we you can't predict what that they want even though it's you know says clearly what the requirements are on that initial application they're always going to dig deeper.

M so yeah to your [clears throat] point one pack your patience because you just don't know and then also know that this the states are all very independent and just because you may submit an application in one state and get a turnaround like that very well could happen but then the next state we're talking about weeks to months while we're waiting on that approval and then to your point about but wait I hired you to do This I mentioned earlier the imaginary dropdown there exists where it's we have got gotten to the state everything that the state has requested on their checklist and their applications and yet there's something else that was not listed anywhere but the state is asking for this information.

So it so the so you're saying that the checklist or the online requirements are not necessarily exhaustive. Correct. And depending on the regulator that is reviewing the application can sometimes determine what in fact you're going to have to submit. So is that is that true of renewals as well as initial licensing? It has been. Okay. It has been. I know there have been times where again with the renewal we submitted everything according to what was on the checklist. And I know there was like a time someone one of the states were like well we want a certificate of good standing from the doicile state and you can scour that checklist as much as you want and nowhere listed on there was this requirement you know still in you know you just have to give them what it is that they're asking for.

So yeah it does happen probably more often than people are familiar with. That's good. And then you mentioned earlier you got to go to the NMLS conference here in Atlanta back in February. Can you share from that one regulator about they got a question about how many applications do you approve the first time? Correct. He asked I'm going to leave the state nameless but in either case he was asked that exact question. how many you know applications get approved their first time through unsubmission and he said zero. Absolutely none of the applications that are submitted get approved their first time. Did this regulator give the answer as to why or can you guess as to why?

I believe the question about why was asked. I do not believe a satisfactory answer was given. there were some vague responses as in like well in some cases we asked for identification for the officers and maybe the driver's license was out of date or something very vague to you know that extent and it was kind of all over the place. But he emphatically stated that not one application that he receives gets approved the first time through. It's crazy. It really is. It really is. I understand it because like they're trying to get to know the applicant as you know they don't want I mean it's their responsibility.

So you know we are not in the business of badmouthing regulators. We actually they are doing their you know mandated you know role to their to their constituents. So we understand it but it is interesting that nobody gets approved the first time. It definitely is. One of the things the regulator said though and I think they were talking about money transmitter licenses specifically when he was saying that you know we want to make sure that no harm will come to you know the residents of our state and when they said that kind of a light bulb went off that it was like okay I can respect the role that you have to play.

You are a governing authority to make sure that you know things are done correctly as it relates to those who live in your state. Yeah, much respect for them. Yeah, no doubt. No doubt. we have a good question in NMLS or in the Q&A about NLS. How do I get forms or enroll in NMLS? So, the best thing would probably be to go to the NMLS resource center. There's a lot of very good information that is there on nmls.org, right? Yeah. Yeah. In fact, forgive me because I'm not sure if that's the exact the exact excuse me URL, but I just Google NMLS resource center to be taken to the link so that you can get there are so many guides and stepbystep yeah information there about how to set up an account for the very first time and you know what is required to do that because you know people you have to understand that you're creating an account in NML MLS and then at some point in time you're going to be submitting applications through NMLS for various licenses and things.

So it's not all the one you know there are different steps and processes and you know how do you get someone the individual account and who all needs an account and how do we link it to the company there's a lot to know and so there's no quick fast answer other than to send you to the resource center to you know try to get that information and I was actually doing some research on there earlier today and I noticed there was a surprising amount of information that has to be mailed in or I was I was surprised to see that because it's a like it's a digital platform so you should just be able to upload a document or but they actually want physical copies of some documents still.

It varies from state to state. There are some states where you're going to upload everything into NMLS and that's it. They're going to be some where you're going to upload it into NMLS and mail the original to the state. Right. So it's just and they're going to be somewhere like with California depending on the license type that you're getting you may do one thing for this license and you're going to do something for this license. So it there are a lot of nuances but it's the regulator it's the regulatory body within that state that's determining how that's it's not NMLS making decisions on how things are done.

It's the regulators themselves that are using that platform to accomplish it the way they want it to be done. Absolutely. Okay. Absolutely. Okay. great question. Please keep them coming. we're sneaking up on two o'clock Eastern. I can't believe it. but I did want to ask like y'all have so much experience and I love getting to ask you questions. I feel like every time we're in the office together, I try to take advantage of that. So, I appreciate you very much. you've worked with a lot of different companies over the years. What sets apart the great compliance teams from the good compliance teams? Like how would you counsel somebody listening today on like I want to be one of those great compliance teams that has as few deficiencies as possible that has a smooth tierree renewal season.

how would you counsel them? I don't know that I could promise you a tearfree. I want to kind of manage these expectations, right? one of the things you want to be in doing this job, one of the things that we have come to realize that you have to be both very detailed oriented and also very flexible. like those two things don't necessarily just inherently go together. But in order to do this and do it well, you need both of those things to be in place. You need to be very detail oriented, making sure you are reading through what it is that the state is asking for, right?

But then also maintaining that sense of flexibility to know that all right, we've done this, we've done that. Deficiencies do not mean death. It just gives me an opportunity for clarification. as you said earlier. So, I would say those kinds of and forgive me it's may not be as you know hardline like this is a tangible thing that you need but flexibility I feel is definitely key to doing this and doing it well. making sure and this is going to be one of those dawnisms but kindness goes a long way. and we understand that everyone who's maintaining these licenses are in this to make money.

This is a business for you, you know, but also understanding that we are all people and those regulators have a lot of pressure that's put on them to get things done, to get them processed, to get through those renewals and things. And so sometimes, and I always like to say as I'm training the new people coming through, you want to be sure to extend grace because at some point in time, you're going to need that grace to be reciprocated to you. So as you are going through this, just kind of keep those things in mind. Yes, approval is the ultimate goal. But you can get there.

It just, you know, how many bodies are you going to leave along the way if you don't in fact impose some kindness and some grace? So love that. I think to add to that so I was an educator too. So forgot that. Yeah. So I think that the companies that have success are the ones who don't procrastinate. Just like students, you get either the early birds, they're the ones who are going to get, you know, approved first and then, you know, and we've seen it like when the portals open up and then the ones that have gotten their information to us first, they get approved first and they don't have to wait, you know, whereas the ones who wait until the end the deadline, they're not going to hear for a couple months because now they've been backlogged.

Sure. So, the biggest advice I give my client is yes, it's not due until 12:31, but if you get it to me by 11:1, I promise I'll get that to you. I'll submit that for you. And then they start seeing a lot of approvals come in. It makes them feel good. Makes us feel good. Then their job is easier. So, I would say definitely to not procrastinate on the submissions. That's so good. That's so good. Is there a way to expedite a renewal? I mean, will regulators let you pay a fee and get a renewal faster? I've seen that on annual reports, but not on licenses.

Okay. Yeah. Annual report. Sometimes you can submit an expedited annual report, but when it comes to license renewals, but it is very much first come, first serve. So, it's a good idea to make sure you've gotten all of your things to in, excuse me, I'm thinking of us, but and you want to make sure you get all of your things in and submitted. the sooner the better so that also if deficiencies come you have the time to deal with that and you're not under the crunch because as we all know technology is great until it's not and NMLS does get what's the word overrun when yeah it will shut down it has happened where it's just been too much activity in the system just could not keep up with it so the last minute is not your friend what you're saying is you don't like dealing with deficiency sees on December 29th.

There's not a hype. Yeah. Zero stars. [clears throat] In terms of going back to some of the worst case scenarios that we talked about, you know, say there is a deficiency that goes past 1231. Is there a drop dead date of like you got to deal with this prior to X date or you are going to lose your license? certain states if you don't have the deficiencies cleared by that date you cannot collect anymore. Okay. but then and then there are certain states that allow reinstatements some that don't hard deadline. No. So it just all varies by state. Okay. But we would not recommend that.

Correct. You know because your specialists are on holiday vacation. You're wanting to go on a holiday vacation and so it just doesn't you know prove to be a good scenario. you wait at all. What's your I mean what date are we talking about? Just you don't have to name a date but like are we talking about like two weeks, two months, a month like as far as like I haven't dealt with a deficiency. So therefore on March one I lost my license. Usually if there's going to be a drop dead date that's going to be entered into the system by the regulator. They will have it in there into so that you will know that this has to be cleared by this particular date.

So yeah, we don't generally have to come up with those dates off the top of our head. That's usually entered in by the regulator. So we will be made aware of ah you got to get this by this date otherwise you're going to Yeah. You know. Yeah. And if they don't have a date it's ASAP. Correct. Especially if it's in Wyoming anymore this very strict state. Okay. Good to know. But it's it's interesting to hear that we're we're there's a lot of runway given in a lot of cases to where like the regulator is not trying to squash your activity. They're trying to give you opportunities to remedy the situation, but you need to pay attention when they do.

Yeah, absolutely. one of the, oh, I do want to say this as well for those who may be going through this renewal season for the very first time when it comes to deficiencies in the system in NMLS, one of the things that was brought to our attention is as you are addressing those deficiencies, let's say that the state says you have to get this form uploaded, right? And so you get the form uploaded on Monday and then you go in and check and you win see on Wednesday that deficiency is still showing, right? and you're like why hasn't the regulator you know cleared this or whatever well whereas the license e will get a notification through NMLS saying that you know this has been assigned to your license regulators do not get a notification saying this deficiency item has been addressed they don't get that there's a way that they can go into the system and see if any activity has taken place however they do not get an immediate notification saying this has been put in the system addressing this issue.

So the regulator has to proactively go and review that renewal. Correct. To see that the item has been uploaded. Yeah. And we don't get the opportunity of seeing the back end as the regulator. So I don't want to use bad terminology, but I just know that they don't get the notifications that we receive. And so there will be times that you will have to reach out to the regulator just to bring it to their attention that this has in fact been addressed. So that may steer them to look at it a little bit sooner than they ordinarily would. Now I do want to say this probably going where I was going.

This does vary from state to state to state. Like one state said, "Hey, as soon as you upload it into the system, shoot us an email and let us know that you've done that." another state has said, "Hey, don't do that, please." we go in on our own every two days or so. So just for just me the way that I tend to do these if there is a depending on what the deadline has been set and how you know far in advance we are dealing with that once I submit it to the system if I know I've got you know plenty of time then I'm going to allow maybe about a week and then I'll go back to see if in fact it has been see that's good from a best practice standpoint because I've got a couple of situations now that I'm working through with some friends trying to help them get some things along and they're trying to figure out what that fine line is between communicating with the regulator versus bringing down the Yes.

Yes. create you do not you do not they are they're people like you said who have you know backlogs and workloads and so yeah depending on yeah the time frame you're dealing with a week is a is a fair you know amount of time to allow. If there's something that you know the deadline is more pressing, then of course you can you know reach out to the regulator sooner. That's right. But yeah, but the beauty of what the two of you do and what our specialists do is we know these regulators so we kind of know like Yeah, maybe give this one two weeks versus a week versus like, hey, let them know like immediately after you send it for sure.

That's that's nice. For sure. we are we have just a couple minutes left. Thank you again to everybody who has tuned in. This has been a joy and honestly like it's been a real joy to get to gone by real quick. It has gone by quick. just clear the queue. What else would you say? What are what's the most important thing you would say to somebody who's listening in as we you know approach the end of the year? You can do this is kind of what I would say. You can you can do this. You know, I do. I remember as a new specialist I remember as a new specialist and looking at the cue of how many renewals I was dealing with coming up on 1231 and just being like, how in the world is this going to happen?

But I will say a plug for NMLS with all of the licenses now that are being transitioned into that system. it really has made license renewal the whole process so much simpler you know and less cumbersome and quite frankly less intimidating. So just I would just say breathe in through the nose out through the mouth. as Jen has said earlier procrastination is definitely the enemy that you want to avoid. Being proactive will work in your favor and just know that you can get through this. you know, even someone who has 50 renewals if you think about it. The window opens November 1st and we're going to December 31st.

So, you're talking less than one renewal a day if you were going to work at that pace. But it can be done. It can be done. And here, you know, at our specialists have been busy preparing for those for our clients. And so, on that resource page, there are the, you know, renewal lists. Everything is just, you know, set for you as far as what's required. So getting all of that just ready before November 1st would be a good homework assignment. Yeah, it's great. Once again, thank you so much to everybody who has tuned in today. This has been has been a blast. Been looking forward to this probably more than you have.

[laughter and clears throat] I know how much y'all love being in front of people, but this has been great. Really appreciate everybody's time today. we are we're here as resources, so please don't hesitate to reach out. you know, cornerstonelicicensing.com. You can get contact info for all three of us and our team. So, we'd be honored to help. If you if you choose to tackle it yourself and kind of hit a wall or hit a hit a bump, you know, please don't hesitate to reach out. We're we try and be as generous with our resources as we can. So, hope you have a great rest of your day and I look forward to seeing you on our next webinar.

Take care. Bye, everyone. Bye.

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