Stakeholder Feedback and SRR Response Journey Maps

Transcription

1 Stakeholder Feedback and SRR Response Journey Maps

2 Stakeholder Feedback and SRR Response - Journey Maps From March to June 2017, the State Regulatory Registry LLC (SRR) requested feedback from stakeholders regarding 42 NMLS 2.0 Journey Maps via the NMLS 2.0 website and Yammer. A journey map is used to provide a user s end-to-end experience in NMLS 2.0 while also displaying the important intersections between different user groups along the way. This document is a compilation of all 42 journey maps, the feedback SRR received from stakeholders, and responses from the feature owners (staff assigned to each feature of NMLS 2.0). Please note, the journey maps are intended to identify actors and process at a high level. Many of the comments we received were very specific and SRR is still in the development process for many of feature requirements and is unable at this time answer every question in detail. However, we will use the questions and feedback to guide us through the various requirements and development phases of 2.0. We have also flagged some questions/suggestions for future follow-up and will request additional input as the development process continues. Thank you to everyone who contributed to reviewing the journey maps! This document is organized by journey map (See Table of Contents) and all stakeholders have been made anonymous. If you have any questions, please nmls2.0feedback@csbs.org.

3 Table of Contents Journey Map 1: Licensure Requirement - pg 4 Journey Map 2: State License Filing Submission for a Company/Branch - pg 10 Journey Map 3: State License Filing Submission for an Individual Licensee - pg 14 Journey Map 4: State License Filing Submission for a Sole Proprietor - pg 18 Journey Map 5: State Renewals for Company/Branch - pg 21 Journey Map 6: State Renewals for an Individual Licensee - pg 24 Journey Map 7: State Regulator Review of Company/Branch Filing - pg 29 Journey Map 8: State Regulator Review of Individual Licensee Filing - pg 32 Journey Map 9: State Regulator Review of Company/Branch Renewal - pg 38 Journey Map 10: State Regulator Review of Licensee Renewal - pg 41 Journey Map 12: Federal Registration (Individual) - pg 44 Journey Map 13: Federal Renewal (Institution) - pg 47 Journey Map 14: Federal Renewal (Individual) - pg 50 Journey Map 15: Account Creation by Company Account Administrator (for State- Licensed Companies) - pg 53 Journey Map 16: Company/Institution Account Administration - pg 57 Journey Map 17: Regulator Account Administration and Portal Configuration - pg 60 Journey Map 18: Employment Relationship Lifecycle - pg 63 Journey Map 19: Effective Dated Changes - pg 70 Journey Map 20: State License Surrender/Withdrawal - pg 74 Journey Map 21: Transitioning a License - pg 78 Journey Map 23: Invoice Management - pg 81 Journey Map 24: Mergers and Acquisitions (M&A) (Federal) - pg 84 Journey Map 25: Using Consumer Access - pg 87 Journey Map 30: Periodic Reporting (MCR) - pg 90 Journey Map 31: Reporting, Data, and Analytics (Company/Institution) - pg 95 Journey Map 32: Reporting, Data, and Analytics (Regulator) - pg 98 Journey Map 33: Surety Bonds Management - pg 101 Journey Map 34: Workload Management for an Institution - pg 104 Journey Map 35: Workload Management for a Regulator - pg 107 Journey Map 37: Pre-Licensure Requirements (Control Person) - pg 110 Journey Map 38: Company/Branch Setup - pg 115 Journey Map 39: Account Creation (Regulator) - pg 118 Journey Map 40: Designated 3 rd Parties - pg 122 Journey Map 41: License Termination - pg 125 Journey Map 43: Account Creation (Individual Licensee) - pg 130 Journey Map 44: State License Filing Submission for an Individual Seeking Licensure - pg 136 Journey Map 48: Employment Relationship Lifecycle (Federal) - pg 140 Journey Map 49: Mergers and Acquisitions (M&A) (State) - pg 143 Journey Map 51: Periodic Reporting (MSBCR) - pg 146 Journey Map 52: Federal Institution End-to-End Journey -pg 149 Journey Map 53: Federal Individual End-to-End Journey (Institution-Driven) - pg 152 Journey Map 54: Federal Individual End-to-End Journey (Individual-Driven) - pg 158 Click on the Journey Map to advance to the page

4 #1 - Pre-Licensure Requirements (Individual State Licensee) Personas: Mary Individual Licensee (State) Journey Map Company Organization User (State) Background: An individual licensee (Mary) wishes to apply for a new license from one or more states and wants to complete all pre-licensure requirements. At the end of the Account Creation journey, Mary selected the option to apply for a new license. A step-by-step guided process now begins which walks her through selecting the license she would like to apply for, understanding what the pre-licensure requirements are, and entering the information / uploading the documents that are required and will be used later in her filings. Note: Some individuals will be seeking both state licensure and federal registration. Human activity System activity Version 2, Delivered 3/14/17 BULK Option to perform action in bulk Preparation Education Testing Criminal Background Check Credit Report Core Data Entry / Document Upload Review Preceding Journey(s) #15 - Account Creation by CAA (for State-Licensed Companies) (if employed) #43 - Account Creation (Individual Licensee) (if not yet employed) Licensees have the option to pay for and complete certain parts of the professional standards requirements prior to filing. Subsequent Journey(s) #3 - State License Application Submission for an Individual Licensee (if employed) #44 - State License Filing Submission for an Individual Licensee With No Employer (if not yet employed) Mary selected the option to apply for a new license in the Account Creation journey. A step-bystep guided process her through the process of selecting the license she would like to apply for, understanding what the requirements are, and entering the information / uploading the documents that are required. User Experiences: When applying for a license, the guided process walks me through all of the steps one at a time. I am able to view detailed instructions on how to complete all of the professional standards requirements. Mary clicks on the education section of the professional standards page and is presented with a summary of her education requirements based on the state(s) selected. Mary selects courses from the NMLS approved education catalog. Upon selecting the courses, Mary is routed to the course providers' websites to complete enrollment and pay for the courses. I am able to easily search the education catalog to find the courses I want to take. My professional standards requirements become part of my NMLS record, and can be used across multiple filings. Mary clicks on the testing section of the professional standards page, creates a new test enrollment window, and schedules / pays for the test she is directed to take based on the state requirements (e.g., National Test Component and/or State Test Component). All scheduling is completed via an NMLS approved testing vendor. Mary takes the required test, and her passing score is then stored as part of her NMLS record. If Mary fails the test, there is a waiting period before she is eligible to retake it, at which point she pays the testing fee again and retakes the test. I can configure the system to be the default payer for all of my licensees' activities in NMLS. Mary clicks on the criminal background check (CBC) section of the professional standards page to schedule fingerprinting via the NMLS approved vendor. Mary also has the option to use existing fingerprints, if still valid (i.e., less than state maximum # of days/years). Mary gets fingerprinted, if necessary. The system will submit the full CBC request at the time of filing submission. The CBC will then be stored as part of Mary's NMLS record. My NMLS record displays the status of all of the pre-licensure professional standards requirements. I am able to quickly view each state's testing requirements (e.g., National Test Component and/or State Test Component). Mary clicks on the credit report section of the professional standards page to authorize a credit report. Mary's credit report will not be pulled until she submits her filing. The credit report will be paid for by, if employed, who is configured as the default payer for all of Mary's activities in NMLS. Once pulled, the credit results become part of Mary's NMLS record. prefers. explanations). Mary Mary? Mary is prompted to answer a series of questions which help her determine which specific license she would like to apply for, such as what type of business and activities she will be engaging in. Mary selects the state(s) where she would like to apply for a license. Mary selects the appropriate license(s) and is provided with a full list of the requirements that need to be completed prior to filing, as well as what information / documents are required. The professional standards requirements can be done in parallel and in whichever order Mary Mary Mary Mary completes her courses, and the course providers upload the results into Education Management System (EMS), which interfaces with NMLS to upload Mary's education credit information. This information is then stored as part of Mary's NMLS record. Mary My passing score is automatically uploaded to NMLS and displayed on my record. Mary Mary Mary Mary enters all core data that will automatically be pre-populated into state filings later (e.g. work history, disclosure questions), and uploads commonly required documents that will be needed (e.g. personal identification, disclosure question Mary views her record in NMLS to confirm all of her professional standards requirements have been satisfied and all core data / documents are present, and she is now ready to begin her filing. If Mary is employed by a company, she can send a task to her Company Organization User () to complete her filing (journey #3), or complete it herself. If she is not yet employed, she completes the filing herself (journey #44). I receive a notification that my test(s) have been successfully scheduled. 4

5 #1 - Pre-Licensure Requirements (Individual State Licensee) NMLS 2.0 Capabilities: NMLS 1.0 Pain Points: Licensees are often unsure of where to start in the licensing process. Varying state checklist requirements (which are external to the NMLS system) create confusion during application submission process. Difficulty locating help resources on the Resource Center. The process of enrolling in courses is all done outside of NMLS. The workflow for test registration and administration causes confusion. While payment is internal, scheduling and managing is external to NMLS. Criminal Background Check process does not include fingerprint scheduling. Payments collected through NMLS are non refundable. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to include State Agency requirements and allow State Agencies to edit these requirements. Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to attach professional standards requirements to a user's record. Ability to see progress while completing the pre-licensure requirements (e.g., visually represent where the user is in the overall workflow). Ability to re-use background and credit checks that are stored in a user's record. 5

6 NMLS 2.0 Journey Map Engagement Journey Map 1 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Based on the lender s location, will it then also show available locations that are near to either the company and/or make it intuitive to show nearest locations based on the MLO s residential address? These are options that we within our vendor now in which feeds into our licensing management system upon scheduling. Assume you're talking about test center locations? The vendor is not expected to change so the information should stay the same but will be more seamlessly integrated into 2.0. Flagged for Future Response Industry Industry If this lives in NMLS, will there be reporting enhancements to pull the scheduled testing and feed into the licensing tracking system? Is it possible in the NMLS 2.0 system to provide (not scores as we know we cannot do that) but on the main dashboard (based on the MLO s tied to the organization) testing metrics? Again, not anything on the Invidia level but metrics around first time pass rates on federal exam, etc. This may not be the right place to bring up (within this journey map) but wanted to throw it out there as information we can possibly add to the Company Dashboard. TBD. We recognize there is a desire for this type of information but it will likely not be displayed on a dashboard. If we display this information it will likely continue to be aggregate information and not segmented by company. X Regulator I think it is a good idea that a company can set payment defaults for their licensees. but does that default end if the individual terminates? 2. If I understand the map correctly, the system will require that all core requirements be completed/authorized prior to submission. This would be really helpful for CBC results to make sure fingerprints are taken prior to the submission. Yes, the default for that individual would end if the individual terminates. Prints and CBC should be authorized prior to license submission. Industry I reviewed Journey Map 1 so far and question why comes in at Step 11? It's a little confusing to me as to why the company user that would initiate a filing for a MLO would wait to come in until a credit report would need to be paid for. Wouldn't the company user,, start this from the beginning or at least come in to pay for the CBC? Maybe I'm reading these wrong as it's a new concept to understand. The journey map does not show it, but there will be option for a company organizational user to be involved much earlier in the process. 6

7 NMLS 2.0 Journey Map Engagement Journey Map 1 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry I have several questions/concerns on Map Can have the ability to schedule edu/test for Mary? as well as pay for those? 2. We work w/ a specific edu provider and a specific person at that provider, using NMLS to schedule things, can we still do that outside the NMLS or be able to utilize the person we've worked w/ for years at the edu provider? 3. When Mary selects the state(s) she wants to apply for she can see the requirements for each state - can access this info as well so he can help the individual understand what they have to do? Yes. The journey map does not show it, but the company organization user will continue to retain many of the same capabilities as the do today. Relationships between a company and course providers will continue to be managed as they are today. The company will also continue to have the ability to schedule and pay for tests. Information on requirements will be displayed early in the account creation/pre-licensure requirements process and will be avail to all. Flagged for Future Response Industry In Journey Map 1 (2) What are the series of questions that will be asked to Mary when she is selecting a license. Most LO s ask us what license type to select. For instance, they would need to know if we are licensed in California under the DBO or BRE. It might be confusing for a new LO. In Journey Map 1 (5) this is a great enhancement. However, we have a relationship with an Education Provider and they get discounts if they use our provider. Will there be a way that Mary can identify her future/current employer to receive the discount. In Journey Map 1 (9, 10, 11): CBC, Credit Report. It would appear by Journey Map that Mary can schedule her fingerprint appointment prior to submitting an application through the Filing tab and paying for them? Is that the case? If so, how does she pay for them outside of the NMLS? It appears that her fingerprint results will upload into the NMLS prior to license application. In Journey Map 1 (13): When Mary applies for her license it appears that either she can pay for the application or send a task to to complete her filing by paying for the application. Is there a function where can send it back to Mary to complete? If we do 2.0 right, some of the existing confusion about which license (i.e. BRE vs DBO) should no longer be a problem. While we will be making improvements to the display of information, the process by which an individual registers for and pays for a course will remain the largely the same. Regarding CBC and credit, they will be required to be submitted/authorized in the system prior to the submission of the application (however, the actual CBC will not be run and shared with regulators until after the application has been submitted). Fees will be paid in NMLS. 7

8 NMLS 2.0 Journey Map Engagement Journey Map 1 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Indicates that Mary needs to be fingerprinted for a criminal background check, but Journey #6, for renewal, indicates that CBCs will no longer be needed with the 2.0 system with the implementation of Rap Back. What is Rap Back and if CBCs are required as part of the initial licensing process, how are CBCs not required for renewals? Rap-back is a process by which authorized recipients (the employer or regulator) can receive ongoing or "real-time" notifications if an individual has been arrested. This is made possible because as part of the rap-back process, the FBI retains the prints on file instead of expunging them like it typically does after a back-ground check is performed. Flagged for Future Response Industry Concerns: Credit and Background portion is at the end of the application phase. What happens if an agent goes through the process of applying and ends up not qualifying for the state license? What are the parameters for application if someone gets to the end of the application and finds out they do not qualify for the state. For example if they have: low credit score, felony conviction on their background (cannot apply in Georgia), Not homestate licensed (New Hampshire application). Will there be a checkpoint for this early on in the application? o Is there a potential for refunds? Is there a possibility to see the results of the credit/background report? Maybe it is saved on the individual s profile. Is there a different view when licensing goes to apply for the individual then if the individual did it themselves? Pros: Able to do application in bits and pieces At the company level, both the MLO and the company organized user will be able to send task back and forth for completion. One of the key objectives of the account creation/pre-licensure requirements process will be to front-load as much information/requirements as possible to applicants are better informed prior even starting the process. Using something like a "decision guide" or "wizard" will enable us to better inform new users about requirements that may preclude them from being licensed. The credit and background are prior to the application process so a lot of the collection of core data and the completion of the four primer prelicensure requirements are all front-loaded. Specific information on views will become more apparent as we get deeper into the requirements and development process. Industry Are the steps in this journey map laid out in the order in which the vision is for MLO s to complete the information? There is a note that alludes to that in the preparation section but wanted to confirm that this applied to the entire document as we moved into testing and education? If these are laid out in the order, we would have feedback on that but we do not feel this is the case but want to confirm. One of the recommendations we have is combining Thank you for the suggestion - we are working to the Credit Report and Core Date Entry into the update the JM to make sure this is feasible. Preparation Category instead of having them as three separate entities. We believe that having the MLO authorize a standard credit report and entering all of her core data (i.e., work history, employment history, disclosure questions) upfront as preparation will be beneficial when it comes to selecting licenses and submitting the filing later in the process. 8

9 NMLS 2.0 Journey Map Engagement Journey Map 1 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Industry Industry Industry Industry In step #1 when there is reference to Mary uploading the required documents. Is this based on the state selection she makes and the checklist of information the state requires? Regarding step #2:why would we add this step for the MLO to fill out when they are sponsored by the company that already has this completed? In our opinion, this information should transfer down from the Company Level to the MLO level based on who they sponsor. A big part of the preparation would also be having the ability to accept the Candidate Agreement and the ability to purchase the SAFE exam. Some portions of the education process should be moved to the preparation phase as well, such as having the correct courses chosen for the states that she will be licensed in. Will only Mary be the one that has the access to Credit Report - Eliminate as its own category, make select state selections as well as picking the a sub-category under Preparation. Please see appropriate education courses or will also have above, under Preparation. the ability to do that for her? Regardless of who has the ability to do it, once selected, will there be automation that is sent from NMLS to the appropriate vendor to drop the course in the MLO s account? Asking this as this could possibly change a lenders current technology in their internal licensing tracking system. Currently we schedule bulk testing in various sites outside of the system and directly through the vendor. Since the proposal is that this live within the NMLS system, will the same functionality exist and schedule MLO s in large batches? Yes, but can be explored in this user story session. This should be explored during the user story session. As the admin, will be able to do this as well. After we got through reading the 12 steps before Only completed courses are reported to NMLS and Review, we were all under the impression that the the MLO's record. MLO was already in her filing, adding the information required, and attesting. Currently in NMLS 1.0, the MLO can only add her information when in the filing, not outside of it. If the MLO is able to add all of her information into the NMLS 2.0 database without a filing being created, we think that would be helpful. Then whenever a filing has been created, all of their required information would prefill each time. One of our biggest takeaways when reviewing the document is that the Pre-Licensing process in NMLS 2.0 needs to be streamlined and clear to the MLO on what steps to take. Enhancing/Updating the existing materials that are within the NMLS Resource will definitely help. The videos that were released in the last few years have been very helpful. A best practice that we have used in our technology is including hovering messages over an area with a brief message explaining what to do or providing a link to the job aid or resource that will assist them with completing it. This has really helped in cutting down the confusion as well as ensuring there is clarity on what the next step needs to be. We anticipate that batch scheduling will not be removed. Flagged for Future Response 9

10 #2 - State License Filing Submission for a Company/Branch Personas: Sally Company Control Person (Branch Manager) Journey Map Company Organization User (State) Ryan Company Control Person (Direct Owner) Sam Regulator Account Administrator (State) Background: A Company Organization User () wishes to apply for a new company and branch license from one or more states. After establishing the company and branch records, populating all core data required for the licenses he wishes to apply for, and uploading all required documents in the Company / Branch Setup journey, selects the option to begin the filing. Meanwhile, Ryan and Sally, designated control persons for the company, have already completed some of the professional standards requirements for the applicable states, and attest to their personal filings initiated by. A guided process begins to walk through the filing process, and the filing is automatically populated from the company and branch records while any required documents are automatically attached from the document repository. Once the filing fee is paid and the filing is attested to, the company, branch, and control person filings are automatically sent to the applicable state regulator (Sam) for review and approval. Human activity System activity Version 4, Delivered 4/14/17 BULK Option to perform action in bulk Preparation Submission Review/Approval #37 - Pre-Licensure Requirements (Control Person) #7 - State Regulator Review of Company/Branch Filing #38 - Company / Branch Setup #30 - Surety Bonds has selected the option to begin the filing after company/branch set up. He is prompted to continue filing for the previously selected states, with the option to add/ remove states. A guided process begins to walk through the filing process. If completed the company/branch set up in a prior sitting, he can select the option to begin the filing from his dashboard. User Experiences: Preceding Journey(s) When applying for a company and branch license, the guided process walks me through the filings step-by-step. adds Ryan and Sally as control persons in the company and branch records, which initiates control person filings for them. Ryan and Sally receive an notifying them that they need to attest, click on a link in the on their mobile device which takes them directly to the filing after logging in, and attest. The core data for the company/branch filings is automatically populated by pulling information from the company and branch records that was entered during the account creation process. Examples include disclosure questions, business activities, identifying information, other trade names, books and records, bank accounts, affiliations, and org structure. confirms the prepopulated core data and completes any additional information that was not automatically populated. This includes confirming all of the branches / branch manager information which is automatically included with the option to add a new branch. BULK is prompted to submit any additional statespecific requirements directly in the system. completes the filing, pays the invoice, attests to all information, and submits. receives immediate confirmation that the filing was submitted as well as an confirmation. The company and branches are assigned an NMLS ID at the time of submission. Ryan and Sally's CBC and credit report are requested at the time of filing. If the filing triggers any configurable system flags (e.g. CBC doesn't match the disclosure responses), receives a notification to correct the discrepancy prior to the filing being submitted to the regulator. I am able to quickly and easily navigate throughout the different sections of the filing and the on-screen status bar keeps track of my progress. I am able to resume a filing I started previously from the license dashboard. If I have a question while I am completing the filing, I can access specific help resources right on the screen I am working on. I am able to seamlessly transition my existing license(s) into NMLS. The system pre-populates filings by pulling information stored in the company, branch, and control person records. Required documents contained in the document repository are automatically attached to the filing (e.g., business plan, financial statements, org. chart, disclosure question supporting documents, permissible investments, etc.). also selects the surety bond that will be submitted with the filing. I am able to complete all steps of the filing process within NMLS, including communicating with other users and uploading/ submitting all documents. I am able to view on-screen help instructions to ensure I upload the correct documents for my disclosure explanations.? I am able to add or delete documents from my company's document repository. I am prompted with a notification that my filing cannot be submitted until the control person attests to their individual filings. Ryan Ryan BULK Sally Sally I receive an notification that a company has created an individual filing on my behalf that requires my attestation. I can attest to my filing on my mobile device, and can get to the attestation page from a link found in the I receive. The system performs a completeness check and notifies me of any missing information before allowing me to submit. I am able to track the status of my license filing during regulator review and view on-screen definitions for each license status within NMLS. Subsequent Journey(s) tracks the review status of the application within NMLS. If necessary, responds to action items or provides additional information requested by Sam, the state regulator. receives confirmation that the application has been approved or denied. If approved, the company can start conducting business. I receive an notification that the Control Persons attested to their filings and the filing was submitted. I am able to pay for multiple licenses at a time. The filings are automatically associated to all Other Trade Names that were entered during company 10 and branch set up

11 #2 - State License Filing Submission for a Company/Branch NMLS 1.0 Pain Points: Company users are unsure of where to start in the licensing process. Varying state checklist requirements (which are external to the Difficulty locating help resources on the Resource Center. Criminal Background Check process does not include fingerprint scheduling. The application workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process. Users do not have the ability to place notes on a filing. (e.g., a note indicating what a filing was for so the fillings can be identified later on.) Lack of data uniformity across states (e.g., certain states care about "St." vs. "Street.") When addressing disclosure questions, if a user answers "Yes", the user does not know what documentation to upload. Lack of settings to enforce specific document uploads based on license type. Agencies have difficulty managing the volume of uploads and identifying changes to documents. States often require documentation that is not on the checklists. Unable to upload certain documentation upfront to provide information the state wants (e.g., work authorization). The upload functionality is limited: unable to provide more than one document at once, size limit constraints, document choices are limited, and wet signature required for some states. Unable to communicate with other users in the system. Control persons unable to update their records without involving other company users. Need to log in and out constantly to attest to filings and changes. Company users currently have to pay for individual licenses one at a time. Users do not receive confirmation that their filing has been successfully submitted. License status names are not intuitive (e.g., Pending- Incomplete) and may not be used the same way across agencies. Applicants are unsure of the status of their application after submitting. NMLS 2.0 Capabilities: Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to request account access from an individual. Ability to re-use background and credit checks that are stored in a user's record. Ability to leave and come back to a filing and resume in the same location (i.e., save and continue). Ability to include State Agency requirements and allow State Agencies to edit these requirements. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to bulk upload data (file upload) or bulk complete actions (multi-record select) in order to complete actions on multiple records at once. Ability for companies to control what steps individuals have access to. Ability to assign tasks to individuals/groups. Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to see progress while completing the filing (e.g., visually represent with a status bar where the user is in the overall filing workflow). Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to communicate with other users within the system. Ability to upload documents for review by the selected state licensing authorities. Ability to upload multiple files at one time. Ability to tag documents with metadata in the document upload section based on workflow and context. Ability for companies to control what steps individuals have access to. Ability to assign tasks to individuals/groups. Mobile capability for core licensing workflow functionality (smartphone, tablet). Ability to notify users via . Ability to send multiple notifications to different parties when actions are taken. Ability to make multiple payments in one invoice similar to a shopping cart concept. Ability to withdraw an application at any time in the process. Ability to have insight into state regulator review progress. 11

12 NMLS 2.0 Journey Map Engagement Journey Map 2 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Flagged for Future Response Regulator Industry For map #2 step 6, what are the prompts? will they be similar to the state specific requirements now accessed via the state map? Step 7: NMLS ID s are created upon license filing and not account creation? I m a little confused on this one. We've received a few questions on step 6. As it's displayed on the map it's currently intended to be a "catch-all" step for any requirements that has not already been met. Hopefully, this step will be rendered obsolete because we've done a better job of displaying and tracking all the requirements early and throughout the process. The exact spot where the NMLS ID is to be issues is still in development. However, it needs to happen before license submission since the applicant needs the ID to complete testing and education. Regulator On Map #2, I agree, I would love to only be able to receive a company application if, and only if, all of the officer CBCs are completed. It would be even better if all the required documents had to be uploaded too before the application could be submitted! It is so frustrating now to receive a company application with not a single Doc Upload available. Understood. Regulator Map #2 I like that the document repository will be submitted with the initial filing, How will the documents be verified? Current pain points include docs being uploaded into the wrong categories. Without all regulators being on board with making sure these items are corrected, it can be burdensome to states that make sure docs are in the correct categories. Will there be a way to ensure that docs are in the correct area? I have concerns about the CBC system checks to see if they match disclosures. I agree completely with the comments made in the next set of maps. These journeys seem to indicate that all document responses will be uploaded to the system; how do we handle CBC responses? Right now, these cannot be uploaded for privacy reasons. It would be great to have them in the system if possible. I do like the ability to get onscreen help to upload the correct documents. This is being explored on how to enforce better compliance automatically in NMLS. 12

13 NMLS 2.0 Journey Map Engagement Journey Map 2 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator When the system pulls core information into the filing, when notices some of that core data is wrong, will his update in the filing change the core data for the entity? So if an entity is already licensed in one state and makes a filing in another state, but as part of the filing notices the disclosure questions need updating - I assume can make the update in the filing he's working on but will that also update the 'core data?' In that scenario, I could see where it may be beneficial, but if an entity is doing a branch filing and the core data pulls trade names into the filing, but the branch isn't going to use a trade name, would the removal of the trade name in the branch filing also remove it from the core data? In that scenario, I could see that being problematic. SRR is starting work on requirements for trade names and we'll take this scenario into consideration. But overall, since all of the information between the company and the branches will be linked going forward any update to core data is going to be also be associated with the branch(es) and trade names. Flagged for Future Response Regulator Regulator Step 8 refers to 'configurable system flags.' I'm not sure if that means flags each regulator can set or something else. I am also not sure I understand the example for the flags - is it saying that the system would validate the individual's disclosure responses against regulatory actions, credit report, CBC, etc and not allow the filing to be submitted until the disclosures match what's found in those other sources? Would the filing be received by the regulator only after the CBC results are posted, if a CBC is required for a control person or branch manager? You're correct. Each licesne will have a number of setting and configurations associated with it that the agency will be able to set as a means to manage approvals and process flows. Yes. 13

14 #3 - State License Filing Submission for an Individual Licensee Personas: Journey Map Mary Individual Licensee (State) Company Organization User (State) Sam Background:, a Company Organization User (State), has been waiting for Mary, an Individual Licensee, to complete all of her pre-licensure requirements so that he can submit a filing on her behalf. Mary completed these requirements in the previous journey, such as populating the core data, uploading required documents, and completing the professional standards requirements. Mary then sent a task to notifying him that he can begin the filing. A guided process begins to walk through the filing process, and the filing is automatically populated from the core data that Mary entered while any required documents are automatically attached from the document repository. After completing the filing, attests, submits payment, and sends to Mary for review and attestation. Once Mary attests, the filing is automatically sent to the applicable state regulator (Sam) for review and approval. Regulator Account Administrator (State) Human activity System activity Version 2, Delivered 3/14/17 BULK Option to perform action in bulk Preparation Submission Review/Approval Preceding Journey(s) #15 - Account Creation by CAA (for State-Licensed Companies) #1 - Pre-Licensure Requirements (Individual State Licensee) Mary to complete all of her pre-licensure activities so that he can submit a filing on her behalf. Mary completed these requirements in the previous journey, and sent a task to notifying him that she has completed her requirements and can begin the filing. A guided process begins to walk through the filing process. User Experiences: If Mary has yet to complete any of the professional standards requirements, the system requires her to complete them before beginning the filing. When applying for a license, the guided process walks me through the filing step-by-step. The application s core data is automatically populated by pulling information from Mary s profile (e.g., address, date of birth, work history, disclosure questions, etc.) that was entered during the prelicensure requirements journey. I am able to quickly and easily navigate throughout the different sections of the filing and the on-screen status bar keeps track of my progress. is prompted to submit any additional state-specific requirements directly in the system. completes the filing, attests to all information, submits payment, and sends to Mary for review and attestation. I am able to complete all steps of the application filing process within NMLS, including communication with other users and uploading/submitting documents. Mary reviews, makes any changes if necessary, and attests. If she makes a change, a task is created for to do a final review before submitting. Once Mary attests, the filing is automatically submitted to the state regulator for review. Requests for Mary's CBC and credit report are automatically submitted. Mary and receive a notification that her filing has been submitted. The system performs a completeness check and notifies me of any missing information before allowing me to submit. Subsequent Journey(s) #8 - State Regulator Review of Individual Licensee Filing BULK confirms the prepopulated core data and completes any additional information that was not automatically populated. If needs any additional information from Mary, he can initiate a task for her to provide the information or upload a document. If Mary has an existing license to transition, enters the license number here. Required documents contained in the document repository are automatically attached to the filing (e.g., personal identification, disclosure question explanations). If the filing triggers any configurable system flags (e.g. CBC doesn't match the disclosure responses), and Mary receive a notification to correct the discrepancy prior to the filing being submitted to the regulator.? BULK Mary and Mary track the status of the application within NMLS. If necessary, they respond to any action items placed by Sam (Regulator) or provide additional information. and Mary receive confirmation that the application has been approved or denied. If approved, the company sponsorship is automatically approved assuming the company is in good standing. I am able to view on-screen help instructions to ensure I upload the correct documents for my disclosure explanations. I can come back to the filing later and my information will be saved, even if I get timed out. Companies have the ability to upload individual filings in bulk. If I have a question while I am completing the filing, I can access specific help resources right on the screen I am working on. Mary Mary Mary I am able to track the status of my application after submitting and have insight into where in the review process my application stands. Mary The system pre-populates my filing by pulling information stored in my record. 14

15 #3 - State License Filing Submission for an Individual Licensee NMLS 1.0 Pain Points: Licensees are often unsure of where to start in the licensing process When a company is granted access by an individual, they receive a access but it does not say who it was that granted access The application workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process Varying state checklist requirements (which are external to the NMLS system) create confusion during the application submission process Difficulty locating help resources on the Resource Center Criminal Background Check process does not include fingerprint scheduling Company users currently have to pay for individual licenses one at a time Applicants are unsure of the status of their application after submitting Unable to communicate with other users in the system The sponsorship approval process is currently an additional step after the license has been approved NMLS 2.0 Capabilities: Ability to combine logical workflow components to facilitate the user experience and reduce confusion/ duplication (e.g., streamlined, intuitive user interface). Ability to see progress while completing the filing (e.g., visually represent with a status bar where the user is in the overall application workflow). Ability to bulk upload data (file upload) or bulk complete actions (multi-record select) in order to complete actions on multiple records at once (e.g., file for multiple licensees). Ability to leave and come back to a filing and resume in the same location (i.e., save and continue). Ability to include State Agency requirements and allow State Agencies to edit these requirements. Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to upload documents for review by the selected state licensing authorities. Ability to communicate with other users within the system. Ability to upload multiple files at one time. Ability to tag documents with metadata in the document upload section based on workflow and context. Ability to re-use background and credit checks that are stored in a user's record. Ability for companies to control what steps individuals have access to. Ability to assign tasks to individuals/groups. Ability to make multiple payments in one invoice similar to a shopping cart concept. Ability to withdraw an application at any time in the process. Ability to send multiple notifications to different parties when actions are taken (e.g. license is approved) Ability to have insight into state regulator review progress. Ability to configure automatic approval (e.g., the ability to automatically approve a sponsorship with an approved license and employment relationship). 15

16 NMLS 2.0 Journey Map Engagement Journey Map 3 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Industry (1) at what point in this journey map is the sponsorship request completed and is it still by? (2) Sponsorship requests aren't always approved when the license is approved. A MLO license may be approved inactively, even with sponsorship, if the related location is pending licensure or is not meeting reasonable commute standards, for example. Referencing step #7 and 8 when does the payment actually go thru/process if Mary makes changes that has to review again? Does it process as soon as submits payment in step 7? SRR is working with the Steering Committee and NMLSPC are looking at ways to better streamline sponsorship within the System. Additional details will become available as we move into the requirements phase of 2.0. Exact point of payment will become more evident as we develop more detailed process flows and the user stories. Flagged for Future Response Industry Industry Regulator Regulator Regulator What does the background check trigger? Does it show Arrest 2011 or Felony conviction What are the specifics to the check? Will the filing be viewable to the regulator after the CBC is actually completed or will we still have applications with pending CBCs? Our Company does not usually pay for our Loan Officer Licenses. In this case it will be helpful to have Mary send her application to us so we can review all of the information she has entered and verify it is complete. At this point we would need the option to send the filing back to Mary so she could complete the filing and pay for her license. (7 & 8) It doesn t seem right that we would submit the filing and pay to Mary attesting to the filing. Map #3 Agree with another Regulator regarding CBCs. One of the items we had discussed previously is that we would like CBC results to be a requirement of the application submission, not just the payment. In addition we would not allow an individual to continue working if their renewal was not approved by 12/31. I have concerns about the CBC system checks to see if they match disclosures. This is understood and will be taken into consideration as we develop the detailed process flows. The only information that will show on the company side is that the CBC has been submitted. Any results will only be viewable by the state regulator or in the case of a registrant, the financial institution. You should have the application after the CBC results have been posted. Understood. Understood. 16

17 NMLS 2.0 Journey Map Engagement Journey Map 3 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator These journeys seem to indicate that all document responses will be uploaded to the system; how do we handle CBC responses? Right now, these cannot be uploaded for privacy reasons. It would be great to have them in the system if possible. I do like the ability to get onscreen help to upload the correct documents. Noted. Flagged for Future Response 17

18 #4 - State License Filing Submission for a Sole Proprietor Personas: Journey Map Bob Sole Proprietor Sam Regulator Account Administrator (State) Background: A sole proprietor (Bob) wishes to apply for new licenses for his company, branch, and self from one or more states. Bob starts the process by creating a single account in NMLS, which allows him to establish records for his company, branch, and self, and also to submit all of his filings. At the end of the account creation process, Bob indicates he is a sole proprietor, which puts him into a special sole proprietor workflow. Bob begins the step-by-step guided process, which helps him to select the appropriate licenses to apply for, walks him through entering core data for his company, branch, and self, upload all required documents, and complete the professional standards requirements. Once these steps are complete, Bob is able to submit a full filing which includes different sections for his company, branch, control person, and individual information. Note: This journey combines elements of account creation, pre-licensure requirements, surety bonds, and company / branch set up into a single sole proprietor workflow. Note: This journey could also apply to small businesses in both the mortgage and non-mortgage industries, but non-mortgage companies would not have individual Human activity System activity Version 2, Delivered 3/16/17 BULK Option to perform action in bulk Preparation Submission Review/ Approval Bob creates a single account in NMLS, which allows him to establish records for his company, branch, and self, and also to submit all of his filings. During the account creation process, Bob's personal and company information is validated and checked against rules for duplicates, he receives his personal NMLS ID, and also indicates he is a sole proprietor, which puts him into a special sole proprietor workflow. A step-by-step guided process begins which walks Bob through the process of selecting the licenses he would like to apply for, understanding what the requirements are, and entering the information / uploading the documents that are required to complete his single filing. User Experiences: Bob Preceding Journey(s) #1 - Pre-Licensure Requirements (Individual State Licensee) #15 - Account Creation by CAA (for State-Licensed Companies) #30 - Surety Bonds #38 - Company / Branch Setup I am able to manage my company, branch, and personal records and submit filings for each through a single login. Bob is prompted to answer a series of questions which helps him determine which specific licenses he would like to apply for, such as what type of business and activities he will be engaging in. Bob selects the appropriate licenses and is provided with a full list of the requirements that need to be completed prior to filing, as well as what information / documents are required. The professional standards requirements can be done in parallel and in whichever order Bob prefers. Bob completes the professional standards requirements needed for the states where he is applying, such as prelicensure education, testing (e.g., SAFE Act), getting fingerprinted, and authorizing a credit check. Bob enters the core data that is needed for his company/branch (e.g., business activities, identifying information, other trade names, books and records, bank accounts, affiliations, and org structure), as well as his self (e.g., address, date of birth, work history, etc.). Bob answers a consolidated set of disclosure questions for his company and self. Bob uploads commonly required documents into his company's document repository for both his company/ branch (e.g., business plan, financial statements, org. chart, permissible investments, etc.) and his self (e.g., personal identification, disclosure question explanations). If Bob executes an electronic surety bond, he will have the option to include it with the filing later, but also has the option to upload any non-electronic surety bonds. Bob initiates his filing. If Bob completed the company/ branch/ individual set up in a prior sitting, he can select the option to begin the filing from his dashboard. Bob also has the option to add any licensees he employs to the filing. The core data for the filings is automatically populated by pulling information from the company, branch, and individual records that was previously entered. Required documents contained in the document repository are automatically attached to the filing (e.g., business plan, financial statements, org. chart, permissible investments, etc.). Bob also selects the surety bond that will be submitted with the filing. #7 - State Regulator Review of Company/Branch Filing #8 - State Regulator Review of Individual Licensee Filing review. submission. Bob Bob selects the state(s) where he would like to apply for his company, branch, and individual licenses. I am able to quickly and easily navigate throughout the different sections of the filing and the on-screen status bar keeps track of my progress. Bob I can come back to the filing later and my information will be saved, even if I get timed out. Bob The system pre-populates filings by pulling information stored in the company, branch, and individual records. Bob Bob confirms the prepopulated core data and completes any additional information that was not automatically populated. If Bob has an existing license to transition, he enters the license number here. I am able to view on-screen help instructions to ensure I upload the correct documents for my disclosure explanations. Bob Bob is prompted to submit any additional state-specific requirements directly in the system. Bob attests to the full filing which includes his company, branch, and individual information. The regulator will receive a consolidated filing for sole proprietors with different sections for the company, branch, and individual that can be delegated to different individuals for The system performs a completeness check and notifies me of any missing information before allowing me to submit. Subsequent Journey(s) ? Individuals who are licensed, or have an intent to become licensed, will be assigned an NMLS ID at account creation.? Bob pays the invoice and submits the application. He receives an onscreen confirmation as well as a confirmation . Requests for Bob's CBC and credit report are automatically submitted. Bob's company and any branches are assigned an NMLS ID at the time of Bob If the filing triggers any configurable system flags (e.g., CBC doesn't match the disclosure responses), Bob receives a notification to correct the discrepancy prior to the filing being submitted to the regulator. Bob tracks the status of the application within NMLS until receiving confirmation that the application has been approved or denied. If necessary, he responds to any action items placed by Sam (Regulator) or provides additional information. If approved, Bob's sponsorship is also approved and he is able to start conducting business. I am able to track the status of my filing after submitting and have insight into where in the review process my filing stands. Bob When applying for a state license, the system provides me with an on-screen list of all the state requirements and fees. Bob I can easily toggle back and forth between my company, branch, and individual filings without having to log out of NMLS. Bob If I have a question while I am completing the filing, I can access specific help resources right on the screen I am working on. Bob I am able to complete all steps of the filing process within NMLS, including communicating with other users and uploading/ submitting all documents. Bob I am able to add or delete documents from my company's document repository. Bob I receive a notification that my filing was successfully submitted. Bob When applying for licenses, the guided process walks me through the filing step-by-step. 18

19 #4 - State License Filing Submission for a Sole Proprietor NMLS 1.0 Pain Points: Sole proprietors need to maintain separate accounts for their company and self and need to log in and out of these accounts to complete required tasks. Licensees are often unsure of where to start in the licensing process. Criminal Background Check process does not include fingerprint scheduling. The application workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process. Varying state checklist requirements (which are external to the NMLS system) create confusion during the application submission process. Difficulty locating help resources on the Resource Center. When addressing disclosure questions, if a user answers "Yes", the user does not know what documentation to upload. Lack of settings to enforce specific document uploads based on license type. Agencies have difficulty managing the volume of uploads and identifying changes to documents. States often require documentation that is not on the checklists. Unable to upload certain documentation upfront to provide information the state wants (e.g., work authorization). The upload functionality is limited: unable to provide more than one document at once, size limit constraints, document choices are limited, and wet signature required for some states. Need to log in and out constantly to attest to filings and changes. Company users currently have to pay for individual licenses one at a time. Users do not receive confirmation that their filing has been successfully submitted. Applicants are unsure of the status of their application after submitting. Unable to communicate with other users in the system. The sponsorship approval process is currently an additional step after the license has been approved. NMLS 2.0 Capabilities: Ability to have a single login/profile, with access and association to multiple entities. Ability to easily toggle between one entity and another for which the user has an administrative or organization role. Ability to re-use background and credit checks that are stored in a user's record. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to see progress while completing the filing (e.g., visually represent with a status bar where the user is in the overall application workflow). Ability to leave and come back to a filing and resume in the same location (i.e., save and continue). Ability to include State Agency requirements and allow State Agencies to edit these requirements. Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to integrate with third party data sources during data entry / upload to validate data (SSN, addresses, etc.). Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to upload documents for review by the selected state licensing authorities. Ability to communicate with other users within the system. Ability to upload multiple files at one time. Ability to tag documents with metadata in the document upload section based on workflow and context. Mobile capability for core licensing workflow functionality (smartphone, tablet). Ability to make multiple payments in one invoice similar to a shopping cart concept. Users are able to withdraw an application at any time in the process. Ability to send multiple notifications to different parties when actions are taken (e.g. license is approved). Ability to have insight into state regulator review progress. Ability to configure automatic approval (e.g., the ability to automatically approve a sponsorship with an approved license and employment relationship). 19

20 NMLS 2.0 Journey Map Engagement Journey Map 4 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Map #4 For a Sole Prop - what if we are able to approve the MLO before the company (this is pretty common)? Do we have the ability to place the MLO app into an Inactive status while the company app is still in review? Or does a Sole Prop have to be processed as one package? We will focus on "sole props" (better knows as "single state operators" or "smaller entities" since the legal structure is more likely a LLC and will dive into the best workflow for them. However, we anticipate that the ability for you to place them into an inactive status would be preserved (see rationalization of statuses topic as well.). Flagged for Future Response Regulator There is a reference to automatic submission of CBC and Credit Report request in step 15 however it is unclear if in the case of a CBC this request covers the actual scheduling of fingerprinting (Live Scan) or has that occurred in another process. Is it happening in Step 6? The scheduling and taking of the prints happens in the pre-licensure process so that when the application is submitted everything is already done. 20

21 #5 - State Renewals for Company/Branch Personas: Journey Map Company Organization User (State) Sally Company Control Person (Branch Manager) Ryan Company Control Person (Direct Owner) Sam Regulator Account Administrator (State) Background: A Company Organization User () wishes to renew company and branch licenses from one or more states, a process completed annually. clicks on the renewal section on his dashboard which activates at the start of each renewal season. selects the licenses he would like to renew, and is guided through a process to determine if anything has changed since the last filing, making any updates as necessary. Ryan and Sally, filings initiated by. finishes the renewal filing, pays the invoice and attests. Once attested, the company, branch, and control person filings are automatically sent to the state regulator (Sam) for review and approval. Note: States that have a renewal deadline earlier than 12/31 can send early renewal notifications to the licensed entities/individuals in their states. Note: This journey also applies to late renewal, which is the same process as renewing a state license, but occurs after the renewal deadline has passed. Late renewal also requires the payment of a late fee. Human activity System activity Version 2, Delivered 3/15/17 BULK Option to perform action in bulk Preparation Submission Review/Approval Preceding Journey(s) #7 - State Regulator Review of Company/Branch Filing can access state-specific renewal requirements year-round from the renewal link on his dashboard. Subsequent Journey(s) #9 - State Regulator Review of Company/Branch Renewal wants to renew his company and branch licenses from one or more states and clicks on the renewal section on his dashboard which activates at the start of each renewal season. If does not want to renew a particular license, he has the option to surrender the license which is covered in journey map #20. User Experiences: selects all of the company and branch licenses that he would like to renew BULK The system sends notifications to, Ryan, and Sally if Ryan and Sally need to update their professional standards requirements such as authorizing a new credit check. Ryan and Sally authorize the credit check, validate their personal information, and attest. CBC's will no longer be needed in 2.0 with the implementation of Rap Back. These requirements can be updated in advance of the renewal process. If Ryan and Sally did not update their professional standards requirements but updated their personal record, they need to submit an attestation. initiates control person filings for Ryan and Sally, who receive an notifying them that they need to attest, click on a link in the on their mobile device which takes them directly to the filing after logging in, and attest. The system walks through a guided process to determine if anything has changed since the last company and branch filings (e.g. any new trade names, disclosure question updates, new control persons or branches, etc.) makes any updates as necessary. The renewal is automatically populated by pulling information from the company and branch records that were reviewed, updated, and confirmed by. resolves any action items that have been placed by Sam over the course of the year. is prompted to submit any additional statespecific renewal requirements directly in the system. completes the renewal, pays the invoice, attests to all information, and submits. receives immediate confirmation that the renewal was submitted as well as an confirmation. tracks the review status of the renewal filing within NMLS. If necessary, responds to action items or provides additional information requested by Sam, the state regulator.? BULK receives confirmation that the renewal has been approved or denied. If approved, the company can continue doing business. Ryan Sally The system automatically notifies users when they need to update their professional standards requirements. The system guides me through each step of the renewal process. I know exactly who placed an action item and can easily communicate with that user within the system if I have questions or need to send documents. I am able to quickly and easily navigate throughout the different sections of the filing and the on-screen status bar keeps track of my progress. f I have a question while I am completing the filing, I can access specific help resources right on the screen I am working on. The system pre-populates my renewal filings by pulling information stored in the company, branch, and control person records. Companies have the ability to upload renewal filings in bulk. When renewing state company and branch licenses, the system provides me with a streamlined process to renew all company and branch licenses at once Ryan I am able to complete all steps of the application filing process within NMLS, including communicating with other users and uploading/ submitting all documents. Sally I receive an notification that a company has created a renewal filing on my behalf that requires my attestation. Ryan Sally I can attest to my filing on my mobile device, and can get to the attestation page from a link found in the I receive. I am able to pay for multiple licenses at a time and receive a notification that my filing was successfully submitted. The system performs a completeness check and notifies me of any missing information before allowing me to submit. I am able to track the status of my renewal filing during regulator review and view onscreen definitions for each renewal status within NMLS. 21

22 #5 - State Renewals for Company/Branch NMLS 1.0 Pain Points: Company users are unsure of where to start in the licensing process. the NMLS system) create confusion during the renewal process. Difficulty locating help resources on the Resource Center. Criminal Background Check process does not include fingerprint scheduling. When receiving a license item, it is not clear who placed the item and there is no easy way to contact that person. The workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process. Users do not have the ability to place notes on a filing. (e.g., a note indicating what a filing was for so the fillings can be identified later on.) States have varying renewal deadlines (e.g., not all states are 12/31). Unable to communicate with other users in the system. Control persons unable to update their records without involving other company users. Need to log in and out constantly to attest to filings and changes. Company users currently have to pay for individual licenses one at a time. Users do not receive confirmation that their filing has been successfully submitted. Renewal status names are not intuitive (e.g., Pending- Incomplete) and may not be used the same way across agencies. Applicants are unsure of the status of their renewal after submitting. NMLS 2.0 Capabilities: Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to request account access from an individual. Ability to re-use background and credit checks that are stored in a user's record. Ability to initiate tasks based on user actions, another user's actions (who created a task for you), or system generated activities. Ability to attach regulator/reviewer contact information to action items/communications. Ability to leave and come back to a filing and resume in the same location (i.e., save and continue). Ability to include State Agency requirements and allow State Agencies to edit these requirements. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to bulk upload data (file upload) or bulk complete actions (multi-record select) in order to complete actions on multiple records at once. Ability for companies to control what steps individuals have access to. Ability to assign tasks to individuals/groups. Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to see progress while completing the filing (e.g., visually represent with a status bar where the user is in the overall filing workflow). Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to communicate with other users within the system. Ability to upload documents for review by the selected state licensing authorities. Ability to upload multiple files at one time. Ability to tag documents with metadata in the document upload section based on workflow and context. Mobile capability for core licensing workflow functionality (smartphone, tablet). Ability to notify users via . Ability to send multiple notifications to different parties when actions are taken. Ability to make multiple payments in one invoice similar to a shopping cart concept. Ability to have insight into state regulator review progress. 22

23 NMLS 2.0 Journey Map Engagement Journey Map 5 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Map #5 If the Company/Branch chooses not to renew, so they have another option other than to surrender? They may want to keep the license through December 31st, but reflect on their record that they chose to let the license go and not expire. Step 6 indicates that the company can choose to make changes once a year. This would not be consistent with making changes to disclosures within 30 days of an event or may give the licensee the impression that records can be updated once a year. This would create additional burden on the regulator during the renewal season. Our state code requires that updates be made immediately when an event occurs, but we do allow up to 30 days as per system policy. Need to understand what other option you're envisioning or what the need is and why? We understand the concern about the need to be able to make changes more than once a year and this will be reflected in the requirements. Flagged for Future Response X Industry State Renewals for Company/Branch: Ideally, step 6 Agreed. on resolving action (license) items should be part of the Preparation phase, not Submission. Preferably before step 5. Reason is some action items may take some time to resolve and may not be able to be completed in time during renewal submission phase. Industry Regulator Step 6: Should any action items placed by a regulator be resolved prior to the renewal opening period? Resolving action items should not wait until you are ready to submit renewals. The subject of RAP Back has been introduced, will there be a comprehensive discussion on how that functionality will work and what happens with renewal CBC requirement if a civil validation file is removed from Rap back functionality? Agreed. Yes. 23

24 #6 - State Renewals for an Individual Licensee Personas: Journey Map Mary Individual Licensee Company Organization User (State) Sam Regulator Account Administrator (State) Background: In order for an individual licensee (Mary) to maintain an active state license, the license must be renewed each year by her company in advance of the state deadline (typically 12/31). A Company Organization User () is responsible for filing for renewal on behalf of Mary. clicks on the renewal section on his dashboard which activates at the start of each renewal season to go to the renewal page, where he can select as many licensees as he wants to initiate renewals for. The licensees, including Mary, receive a task to review and attest to the filing, and make any changes as necessary. Once Mary attests, pays the invoice and submits the renewal to the state regulator for approval. Note: This journey also applies to late renewal, which is the same process as renewing a registration but occurs after the renewal deadline has passed. Late renewal also requires the payment of a late fee. Human activity System activity Version 2, Delivered 3/14/17 BULK Option to perform action in bulk Preparation Submission Review/Approval Preceding Journey(s) #8 - State Regulator Review of Individual Licensee Filing Mary receives reminders throughout the year to complete her continuing education requirements. The company can be the default payer for renewal fees, or the invoice can be delegated to the licensee. Subsequent Journey(s) #10 - State Regulator Review of Individual Licensee Renewal Mary's license and clicks on the renewal section on his dashboard which activates at the start of each renewal season. User Experiences: Mary Mary is taken to the renewal page and presented with a list of licensees that he can easily search and filter, and checks the box next to Mary's name and as many other licensees as he wants to renew to initiate the filings. BULK The system prompts to initiate a task for Mary if she needs to update her professional standards requirements, such as authorizing a new credit check. CBC's will no longer be needed in 2.0 with the implementation of Rap Back. Mary receives a notification that a renewal was initiated on her behalf, and logs into the system to review. The system walks Mary through a guided process to determine if anything has changed since the last filing. Mary makes any updates as necessary, which notifies, and uploads supporting documentation if her disclosure responses changed. The renewal is automatically populated by pulling information from Mary's record. Mary attests to all information in the filing. pays the invoice and submits it to the state regulator for review. 's invoice payment screen shows all outstanding filings, and he can select which invoices to pay. Mary and receive notifications that the filing was submitted to the state regulator. BULK Alternate Step: If Mary made any changes to the filing, the filing is sent back to for final review, and is submitted once reviews, attests, and pays the invoice. When renewing my state licenses, the system provides me with a streamlined process to renew all licenses at once. The system guides me through each step of the renewal process. I am able to track the status of my renewal after submitting and have insight into where in the review process my application stands. Mary Mary Mary The system automatically notifies users when they need to update their professional standards requirements. I am able to view on-screen help instructions to ensure I upload the correct documents for my disclosure explanations. I know exactly who placed an action item and can easily communicate with that user within the system if I have questions or need to send documents. Mary Mary or Mary resolve any action items that have been placed by Sam over the course of the year. Mary is prompted to submit any additional statespecific renewal requirements directly in the system. I am able to quickly and easily navigate throughout the different sections of the filing and the on-screen status bar keeps track of my progress. Companies have the ability to upload renewal filings in bulk. I can come back to the filing later and my information will be saved, even if I get timed out. Mary Mary Mary If I have a question while I am completing the filing, I can access specific help resources right on the screen I am working on. The system pre-populates my renewal filing by pulling information stored in my record. I am able to complete all steps of the renewal filing process within NMLS, including communicating with other users and uploading/ submitting all documents. Mary tracks the status of the renewal within NMLS. If necessary, he or Mary responds to any action items placed by Sam (Regulator) or provides additional information. By renewing before the deadline, Mary can continue originating loans, even if the state does not approve by 12/31. The system performs a completeness check and notifies me of any missing information before allowing me to submit. By paying at attestation, the company avoids overpaying renewal fees for licensees who do not renew. I can configure the system to be the default payer for all of my licensees' activities in NMLS. and Mary receive confirmation that the renewal has been approved or denied. If approved, the company sponsorship is automatically renewed. Mary is able to continue originating loans. 24

25 #6 - State Renewals for an Individual Licensee NMLS 1.0 Pain Points: Licensees are often unsure of where to start in the licensing process. Criminal Background Check process does not include fingerprint scheduling. When receiving a license item, it is not clear who placed the item and there is no easy way to contact that person. The application workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process. States have varying renewal deadlines (e.g., not all states are 12/31). Varying state renewal checklist requirements (which are external to the NMLS system) create confusion during the renewal process. Difficulty locating help resources on the Resource Center. Company users currently have to pay for individual licenses one at a time. Companies often overpay for licensees who do not end up renewing. Applicants are unsure of the status of their application after submitting. Unable to communicate with other users in the system. The sponsorship approval process is currently an additional step after the license has been approved. NMLS 2.0 Capabilities: Ability to re-use background and credit checks that are stored in a user's record. Ability to initiate tasks based on user actions, another user's actions (who created a task for you), or system generated activities. Ability to attach regulator/reviewer contact information to action items/communications. Ability to combine logical workflow components to facilitate the user experience and reduce confusion/ Ability to see progress while completing the filing (e.g., visually represent with a status bar where the user is in the overall application workflow). Ability to bulk upload data (file upload) or bulk complete actions (multi-record select) in order to complete actions on multiple records at once (e.g., file for multiple licensees). Ability to leave and come back to a filing and resume in the same location (i.e., save and continue). Ability to include State Agency requirements and allow State Agencies to edit these requirements. Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to upload documents for review by the selected state licensing authorities. Ability to communicate with other users within the system. Ability to upload multiple files at one time. Ability to tag documents with metadata in the document upload section based on workflow and context. Ability for companies to control what steps individuals have access to. Ability to assign tasks to individuals/groups. Ability to make multiple payments in one invoice similar to a shopping cart concept. Ability to send multiple notifications to different parties when actions are taken (e.g. license is approved) Ability to have insight into state regulator review progress. Ability to configure automatic approval (e.g., the ability to automatically approve a sponsorship with an approved license and employment relationship). 25

26 NMLS 2.0 Journey Map Engagement Journey Map 6 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator For Map #6 - (1) Is it correct to assume there is a Journey Map for sponsored individuals who are handling the renewal themselves? I don't think we want to hand control of an individual's license completely to the sponsoring company. (2) Authority to work after 12/31 with an unapproved renewal shouldn't be automatically granted. I'm not clear if an "on hold" option will still exist, but if the state is purposefully not processing the renewal (placed it on hold) then the person shouldn't be able to work. Also, this could encourage some to renew on 12/31 because they know the regulatory won't be able to review the renewal for at least some period of time in the new year, during which they can work. While this sponsoring company may assist in updating a record and preparing for renewals, the individual will still be responsible for verifying the information and attesting to the information as part of the renewal process. SRR agrees that authority to work after 12/31 with an unapproved shouldn't be automatically granted and we'll address this as part of requirements. Flagged for Future Response Regulator Map #6 Same concerns regarding the updates and response to action items over the last year. Step 9 - concerns with the MLO being allowed to originate after 12/31 if the renewal has not been approved. We would not allow an individual to originate if the renewal had not yet been approved. SRR agrees and this will be addressed as part of requirements. 26

27 NMLS 2.0 Journey Map Engagement Journey Map 6 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry 1. Can there be multiple people as 'defaults' to view and submit renewals for Mary (as well as for the initial application process in Map 1/3). B/c if is out sick and something needs to be taken care of for Mary on renewals (or initial application) can someone else (say the licensing manager) submit/view as well? or only? 2. opts to renew licensing for Mary, what if Mary doesn't want to renew some? Will there be the option to 'do not renew' still? Just want clarification here. 3. What about if there is a 'prevent renewal' on a license, how will that look in this process? the same as currently, where we have to get the item cleared up and then go back in to submit renewal? 4. Referencing #9 on this map, will ALL states abide by the rule that if Mary submits renewal for her state(s) prior to deadline that she can continue to originate after 12/31 if the state doesn't have her in a 'renewal approved' status? As currently states like MO and NY require Mary to be in renewal approved status by 1/1 in order to continue business. Multiple questions: 1. Yes - users will have multiple abilities and ultimately the licensee will determine what happens with renewal. For DNR - we are discussing this. For renewal status - we are discussing this with states. Flagged for Future Response Industry Will all sponsored MLO licenses be available in our Renewal page? We do not pay for 99% of our Loan Officer License renewals. If we do not click the box next to their name, can they pay for the renewal? It is better the way it is since we can ask the LO s that we have authorization to pay their renewals to Attest to Company and we won t have 900+ LO licenses in our renewal page. Step 3: What is a Rap Back and how does that eliminate the need for CBC submission? Step 9: By renewing before the deadline, Mary can continue originating loans, even if the state does not approve by 12/31. Multiple states require renewal approval before 12-31, so we are wondering if this step is not taking that into account. Renewal: your view should be customized based on what you are doing and both payment options will be available. RAP Back is an automated response from the FBI on any subsequent record updates once an individual has been enrolled. For Step 9: yes, it will. We are working with states to clarify and streamline this. 27

28 NMLS 2.0 Journey Map Engagement Journey Map 6 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Pro: Back and forth between agent and licensing. Pro: Agent able to review MU4 before submission (Update residential address, etc.) What happens with expired live scans when applying for renewals? Fingerprints must be up to date whenever they are used for a new CBC result. Flagged for Future Response Regulator Regulator Same concerns regarding the updates and response to action items over the last year. I disagree with the can continue to work in Step 9 if the renewal was filed prior to the deadline. This should be configurable by state or at least states should have the ability to set a flag on those that cannot continue to originate. Understood. We agree and this has been corrected on subsequent edits of the journey map. 28

29 #7 - State Regulator Review of Company/Branch Filing Personas: Journey Map Company Organization User (State) Ryan Company Control Person (Direct Owner) Sally Company Control Person (Branch Manager) Sam Regulator Account Administrator (State) Fernando Regulator Organization User (State) Jessica Regulator Organization User (State) (Credit & Criminal Background Check Specialist) Preparation Background:, a Company Organization User, has submitted a company and branch filing for new licenses that was based on the requirements and fees previously established by the state's Account Administrator, Sam, in the state's regulator portal. The filing also contains the control person filings for Ryan and Sally. The system performed a completeness check prior to allowing the filing to be submitted. The filing runs through regulator-defined rules/thresholds and any items that require additional review are flagged (e.g. low credit score, criminal history, etc.). Sam receives an Initial Review Task on his dashboard when the filing is received, and from his dashboard can assign review tasks to Fernando and Jessica. Tasks can be manually or automatically assigned based on configurable rules, or can be claimed by reviewers. Fernando and Jessica can access all information relevant to the filing from their review filing dashboard as they complete their review tasks. They complete their review checklists in the system, can place notes on the filing, and place action items if there are any deficiencies or they have questions to ask, Ryan, or Sally. After any action items are resolved and the review is complete, the filing is approved and the licenses are issued for the company and branch. Note: State regulators will receive a consolidated filing for sole proprietors with different sections for the company, branch, and individual that can be delegated to different individuals for review. Review Version 2, Delivered 3/15/17 BULK Option to perform action in bulk Outcome Preceding Journey(s) #17 - Regulator Account Administration #2 - State License Filing Submission for Company/Branch License requirements and fees, and defined rules/thresholds for flagged items established in #17 - Regulator Account Administration Subsequent Journey(s) N/A a Company Organization User, has submitted a filing for new licenses from a state for his company and branch. The filing was based on the requirements and fees previously established by the state's Account Administrator, Sam, in the state's regulator portal. The filing also contains the control person filings for Ryan and Sally. User Experiences: The system performed a completeness check prior to allowing to submit, thereby ensuring that the state receives a complete filing that meets all requirements. The filing runs through regulatordefined rules/ thresholds and any items that require additional review are flagged. In this case, Ryan's (Control Person) low credit score and criminal history are flagged items. Sam receives an Initial Review Task on his dashboard when the filing is received, and from his dashboard can assign review tasks. Tasks can be manually or automatically assigned based on configurable rules, or can be claimed by reviewers. Tasks can also be reassigned for specialization or workload balancing. Sam's dashboard displays all open tasks, assigned tasks, overdue tasks, metrics, etc. Sam creates a task for Jessica to review Ryan's (Control Person) credit report and CBC, and another task for Fernando to review the rest of the filing. Fernando and Jessica access all information relevant to the filing from their review filing dashboard as they complete their review tasks (e.g. filing, attachments, regulatory actions, license history, notes from other regulators, etc.). This includes all information on the company, branch, and Control Persons. Fernando and Jessica complete their review checklists in the system, and place action items if there are any deficiencies or they need to ask, Ryan, or Sally any questions. They can also include internal notes, upload documents, set due dates for the action items, and their contact information is included with the action item., Ryan, and Sally receive a task to complete on their dashboard when an action item is placed. They are notified via , click a link in the taking them to the NMLS login page, log in, and are taken to the task. They resolve the action items by responding with additional information or uploading documents. Fernando and Jessica receive Follow-Up Review Tasks to complete when the specific action items that they placed are resolved. They complete the tasks and finalize their review. Fernando, tasked with conditionally approving or rejecting the filing, makes a determination. They can also place additional action items for, Ryan, or Sally if necessary. I am able to configure and The system performs a I receive notification of items If I have a question while I am My streamlined and customized update the specific items completeness check prior to that have been flagged for reviewing the filing, I can access dashboard helps me stay and fees that are required allowing a licensee to submit a additional review which allows specific help resources right on organized by displaying my work to apply for a license in my filing, ensuring that I receive a Sam me to prioritize my workload. items in a prioritized manner. state. Sam the screen I am working on. complete filing. Sam Sam Sam Sam Sam receives a Final Review Task, where he does a secondary review of Fernando's decision, and either approves or denies the filing. He can also create a task for Fernando to obtain additional information. The system generates a notification for, Ryan, and Sally and other configured users at their company with the final decision. If approved, the company and branch licenses are officially issued and the license record is updated in NMLS. I am able to customize how tasks are assigned or claimed at my agency. Sam I can easily assign tasks via my dashboard and the system automatically assigns other tasks. Jessica Fernando The filing and relevant information is presented to me in an easy-to-use format. Jessica Fernando I can communicate with other users in the system to get the information I need. Jessica Fernando I am able to complete all steps of the filing review process within NMLS, including communicating with other users and downloading all documents. Sam I am able to send notifications to users in the system to keep them updated on the status of a task or outcome. I can easily identify who placed an action item and their contact information is displayed right in the task. 29

30 #7 - State Regulator Review of Company/Branch Filing NMLS 1.0 Pain Points: Varying state checklist requirements (which are external to the NMLS system) create confusion during the filing submission process. Regulators have to deal with incorrect interpretation of checklist requirements. The system allows licensees to submit filings that have missing or insufficient information. The review workflow is complex, not intuitive, and does not provide transparency into what items I need to review. Difficulty locating help resources on the Resource Center. The worklist is very confusing, does not allow a user to prioritize items, and contains items that don't even require action. Users are unable to customize the view of a worklist. The worklist doesn't provide an accurate picture of a user's true workload. No ability to mark items as resolved or clear them from the worklist. There is no easy way to assign tasks or send notifications or reminders. Users don't know how to prioritize their work. There is no easy way to sort and filter records. The filing often contains information that isn't required by a state, but the regulator has to review it anyways. Too many clicks required to view details of a work item, create license items, update license status, etc. Unable to communicate with other users in the system. When a regulator places an action item, the licensee has no idea who placed it or how to contact them. There is no ability to track changes to records or provide an audit trail of actions. There is no ability to place internal notes on a filing. There are a number of items and tasks that have to be performed outside of NMLS (e.g. submitting forms, paying invoices, etc.). Regulators often wait for items to be received outside of the system before they can review a filing. The sponsorship approval process is currently an additional step after the license has been approved. Applicants are unsure of the status of their application after submitting. The system does not provide licensing history. NMLS 2.0 Capabilities: Ability to include state requirements and allow state agencies to edit these requirements. Ability to set regulator fees and other configurable license requirement and workflow settings. Ability to dynamically require additional steps or uploaded document(s) based on pre-defined rules on fields such as license type and state. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to check submitted forms for completeness against requirements and provide immediate user feedback on gaps/errors/omissions. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability for regulators to control what steps individuals have access to. Ability to assign tasks to individuals/groups. Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to customize the view of the dashboard by task, industry, company, or other attribute. Ability to prioritize and assign workload. Ability for system to identify records that pass all regulator-defined checks with ability to single-click approve that population. Ability to configure auto-approval thresholds (e.g., credit checks, CBC, etc.). Ability to auto-assign certain tasks by state, work item type, etc. Ability to secure data downloaded from the system to protect PII and other sensitive data. Ability to show and access version history of uploaded documents. Ability to limit access to sensitive documents / data in the system by group / user. Ability to see other state regulator notes on credit report reviews (need to think through privacy concerns). Ability to track all actions, activities, and changes with an audit trail. Ability to send reminder notifications for pending/incomplete tasks. Ability to restrict some communications to regulator access only. Ability to set due dates. Ability to attach regulator/reviewer contact information to action items/communications. Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to download documents for review. Ability to communicate with other users within the system. Ability to ensure positive confirmation of what is being worked by the regulator (and who is working it, particularly where problems are identified). Ability to bulk upload data or bulk complete actions (multi-record select) in order to complete actions on multiple records at once (e.g., approve multiple licensees). Ability to send multiple notifications to different parties when actions are taken (e.g. license is approved) Ability to configure automatic approval (e.g., the ability to automatically approve a sponsorship with an approved license and employment relationship). Ability to provide insight into state regulator review progress. 30

31 NMLS 2.0 Journey Map Engagement Journey Map 7 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Journey Map 7 describes a process where Thanks! We think so too and are excited to Regulator users may set Action Items from a demonstrate this to folks soon. "Review" dashboard. The Company user than responds directly to those action items. To me, this seems like a huge step forward, as it directly connects an action item and the company response, instead of having to manage it outside of the system and significantly lowers the follow up burden.. Additionally, I assume this "Review Dashboard" is describing one location where Regulator users can view company information, and directly set Action Items. If this is the case, it is a great idea. Flagged for Future Response Regulator Would the due dates set be delivered to the applicant or are they just for the regulator? It would be great to give applicants due dates through the tasks assigned! Due dates without insight for applicants is a pain point and we want to "liberate the data" and be transparent on what deadlines are for an applicant/licensee and also allow states to track internal, non-public deadlines. 31

32 #8 - State Regulator Review of Individual Licensee Filing Personas: Journey Map Company Organization User (State) Mary Individual Licensee (State) Sam Regulator Account Administrator (State) Fernando Regulator Organization User (State) Jessica Regulator Organization User (State) (Credit & Criminal Background Check Specialist) Background: has submitted a filing on behalf of Mary for a new license that was based on the requirements and fees previously established by the state's Account Administrator, Sam, in the state's regulator portal. Mary's filing is one of 100 filings received by the state that day. The system performed a completeness check prior to allowing the filings to be submitted. The filings run through regulator-defined rules/thresholds and any items that require additional review are flagged (e.g. low credit score, criminal history, company hasn't renewed yet, etc.). If there are no flagged items, the system is configured to allow for one click-approval of the filing. The other 99 filings do not trigger any flags, allowing Sam to select all from his dashboard and approve. Mary's filing, however, is flagged by the system and requires manual review. Sam receives an Initial Review Task on his dashboard when the filing is received, and from his dashboard can assign review tasks to Fernando and Jessica. Fernando and Jessica can access all information relevant to Mary's filing from their review filing dashboard as they complete their review tasks, and complete their review checklists in the system. They place action items if there are any deficiencies or they have questions to ask Mary or. After any action items are resolved and the review is complete, the filing is approved and the license issued to Mary. Human activity System activity Version 2, Delivered 3/14/17 BULK Option to perform action in bulk Preparation Review Outcome Preceding Journey(s) #17 - Regulator Account Administration #3 - State License Filing Submission for an Individual Licensee License requirements and fees and defined rules/ thresholds for flagged items established in #17 - Regulator Account Administration Subsequent Journey(s) N/A a Company Organization User, has submitted a filing on behalf of Mary, an Individual Licensee, for a new license from a state. Mary's filing is one of 100 filings received by the state that day. The filings were based on the requirements and fees previously established by the state's Account Administrator, Sam, in the state's regulator portal. User Experiences: The system performed a completeness check prior to allowing the user to submit, thereby ensuring that the state receives complete filings that meet all requirements. The filings run through regulator-defined rules/ thresholds and any items that require additional review are flagged. 99 of the filings do not trigger any flags, allowing Sam to select all from his dashboard and single-click approve. In Mary's case, her low credit score and criminal history are flagged items, requiring manual review. Sam receives an Initial Review Task on his dashboard when Mary's filing is received, and from his dashboard can assign review tasks. Tasks can be manually or automatically assigned based on configurable rules, or can be claimed by reviewers. Tasks can also be reassigned for specialization or workload balancing. Sam's dashboard displays all open tasks, assigned tasks, overdue tasks, metrics, etc. In this case, Sam creates a task for Jessica to review Mary's credit report and CBC, and another task for Fernando to review the rest of Mary's filing. Fernando and Jessica access all information relevant to Mary's filing from their review filing dashboard as they complete their review tasks (e.g. filing, attachments, regulatory actions, license history, notes from other regulators, etc.). Fernando and Jessica complete their review checklists in the system, and place action items if there are any deficiencies or they need to ask Mary or questions. They can also include internal notes, upload documents, set due dates for the action items, and their contact information is included with the action item. receives a task to complete on his dashboard when an action item is placed. He is notified via , clicks a link in the taking him to the NMLS login page, logs in, and is taken to the task. He then resolves the action item by responding with additional information or uploading documents. Fernando and Jessica receive Follow-Up Review Tasks to complete when resolves the specific action items that they placed. They complete the tasks and finalize their review. Fernando, tasked with conditionally approving or rejecting the filing, makes a determination. They can also place additional action items for if necessary. I am able to configure and The system performs a completeness I receive notification of items that If I have a question while I am My streamlined and customized update the specific items and check prior to allowing a licensee to have been flagged for additional reviewing the filing, I can access dashboard helps me stay fees that are required to apply submit a filing, ensuring that I review which allows me to specific help resources right on organized by displaying my work Sam for a license in my state. Sam receive a complete filing. Sam prioritize my workload. Sam the screen I am working on. Sam items in a prioritized manner. Sam Sam receives a Final Review Task, where he does a secondary review of Fernando's decision, and either approves or denies the filing. He can also create a task for Fernando to obtain additional information. The system generates a notification for and Mary with the final decision. If approved, Mary's license is officially issued and the license record is updated in NMLS. I am able to customize how tasks are assigned or claimed at my agency. Sam I can easily assign tasks via my dashboard and the system automatically assigns other tasks. Jessica Fernando The filing and relevant information is presented to me in an easy-to-use format. Jessica Fernando I can communicate with other users in the system to get the information I need. Jessica Fernando I am able to complete all steps of the filing review process within NMLS, including communicating with other users and downloading all documents. Sam I am able to send notifications to users in the system to keep them updated on the status of a task or outcome. Mary I can easily identify who placed an action item and their contact information is displayed right in the task. 32

33 #8 - State Regulator Review of Individual Licensee Filing NMLS 1.0 Pain Points: Varying state checklist requirements (which are external to the NMLS system) create confusion during the filing submission process. Regulators have to deal with incorrect interpretation of checklist items. The system allows licensees to submit filings that have missing or insufficient information. The review workflow is complex, not intuitive, and does not provide transparency into what items I need to review. Difficulty locating help resources on the Resource Center. The worklist is very confusing, does not allow a user to prioritize items, and contains items that don't even require action. Users are unable to customize the view of a worklist. The worklist doesn't provide an accurate picture of a user's true workload. No ability to mark items as resolved or clear them from the worklist. There is no easy way to assign tasks or send notifications or reminders. Users don't know how to prioritize their work. There is no easy way to sort and filter records. The filing often contains information that isn't required by a state, but the regulator has to review it anyways. Too many clicks required to view details of a work item, create license items, update license status, etc. Unable to communicate with other users in the system. When a regulator places an action item, the licensee has no idea who placed it or how to contact them. There is no ability to track changes to records or provide an audit trail of actions. There is no ability to place internal notes on a filing. There are a number of items and tasks that have to be performed outside of NMLS (e.g. submitting forms, paying invoices, etc.). Regulators often wait for items to be received outside of the system before they can review a filing. The sponsorship approval process is currently an additional step after the license has been approved. Applicants are unsure of the status of their application after submitting. The system does not provide licensing history. NMLS 2.0 Capabilities: Ability to include state agency requirements and allow state agencies to edit these requirements. Ability to set regulator fees and other configurable license requirement and workflow settings. Ability to dynamically require additional steps or uploaded document(s) based on pre-defined rules on fields such as license type and state. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to check submitted forms for completeness against requirements and provide immediate user feedback on gaps/errors/omissions. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability for regulators to control what steps individuals have access to. Ability to assign tasks to individuals/groups. Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to customize the view of the dashboard by task, industry, company, or other attribute. Ability to prioritize and assign workload. Ability for system to identify records that pass all regulator-defined checks with ability to single-click approve that population. Ability to configure auto-approval thresholds (e.g., credit checks, CBC, etc.). Ability to auto-assign certain tasks by state, work item type, etc. Ability to secure data downloaded from the system to protect PII and other sensitive data. Ability to show and access version history of uploaded documents. Ability to limit access to sensitive documents / data in the system by group / user. Ability to see other state regulator notes on credit report reviews (need to think through privacy concerns). Ability to track all actions, activities, and changes with an audit trail. Ability to send reminder notifications for pending/incomplete tasks. Ability to restrict some communications to regulator access only. Ability to set due dates. Ability to attach regulator/reviewer contact information to action items/communications. Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to download documents for review. Ability to communicate with other users within the system. Ability to ensure positive confirmation of what is being worked by the regulator (and who is working it, particularly where problems are identified). Ability to bulk upload data or bulk complete actions (multi-record select) in order to complete actions on multiple records at once (e.g., approve multiple licensees). Ability to send multiple notifications to different parties when actions are taken (e.g. license is approved) Ability to configure automatic approval (e.g., the ability to automatically approve a sponsorship with an approved license and employment relationship). Ability to provide insight into state regulator review progress. 33

34 NMLS 2.0 Journey Map Engagement Journey Map 8 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Regulator 1: I have some concerns about the role "" has in resolving the license items placed on "Mary's application in Journey Map #8. While may be paying for the license, this is Mary's individual record/license and she should receive all notifications and be responsible for addressing all license items that pertain to her record. In addition, many communications involve confidential information that cannot be privy to. As I understand the map, it appears that the company organization user is tasked with resolving issues that should be resolved by the individual license applicant. Hopefully, my comment makes sense! This is for illustrative purposes only. Mary is ultimately responsible and is merely there to assist Mary in resolving appropriate items. We will make it clear in the process. Flagged for Future Response Regulator 2: I understand the concern. This is also an area of great inefficiency in the licensing process (resolving app deficiencies). I think there is a way though from both a legal and philosophical viewpoint that as regulators we can be comfortable with having a more prominent role in this scenario. However, when it comes to CBC info we have to be very mindful of the FBI's dissemination restrictions whether it be license items within the system or direct contact with the MLO/employer. Regulator The map appears to be missing the notification to Mary when the regulator requests something or has additional questions. Is the process that the regulator identifies something on the application which needs a response, is notified and he completes the requirement without any involvement from Mary? Mary would be involved and a notification will be added. 34

35 NMLS 2.0 Journey Map Engagement Journey Map 8 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator 1. Due date addition is pertinent and should be Yes. communicated to the applicant. Idaho has a 60 day threshold before the application is deemed withdrawn, so this would be very helpful. 2. If is receiving an with a link to log into the system, will that contain the action item, as well? Currently, individuals receive an for each license item added and they do not use them as a start point to log into NMLS to review the action items needed. Their first response is to call or the state. I feel like this can be streamlined to avoid the additional burden on the regulator. 3. Individuals should be involved in changes made to their filing. Currently, we cannot communicate with the employer regarding CBC or credit action items. 4. Would love to be able to communicate through the system! If possible, I would like to be able to communicate with all parties involved in the app in one place, including the company compliance department, when needed or allowable. Flagged for Future Response 35

36 NMLS 2.0 Journey Map Engagement Journey Map 8 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Regulator 1: For the contact info part, would it be possible to automatically include contact information when a license item is posted? The only issue with that is if you wanted the licensee to contact somebody other than the person who posted it. So possibly have it automatically show up but have a way that it can be edited if need be. Yes. Flagged for Future Response Regulator 2: I think having at least that type of capability is important. As a regulator, I would like to have several options to select from when the system automatically adds regulator contact info to a license item. Maybe a 3-5 option drop down box that is editable by the admin along with a custom option the user can input. Also, there needs to be a mechanism that notifies the regulator when a license item has been worked on/updated. Regulator 3: I second Regulator 2's comment on the ability to know when a license item issue has been worked on/updated. When we put a deficiency on a issue related to MU2 person at a company but that person doesn't have a MLO license, when that person updates their information, we don't always get a work item to let us know the change has been made. It makes it difficult because try to tell people they don't have to us when they make a change, because we get a work item, but we can't do that for MU2 people because we don't always get a work item. 36

37 NMLS 2.0 Journey Map Engagement Journey Map 8 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Regulator 1: I would much rather have notifications come through the system than have the individual or company send an every time they complete something. The s are very time consuming and duplicate the efforts of our staff to resolve issues. Noted. Flagged for Future Response Regulator Regulator 2: I would much rather have notifications come through the system than have the individual or company send an every time they complete something. The s are very time consuming and duplicate the efforts of our staff to resolve issues. Regulator 3: I agree with too many s and I hate having to request licensees to once they do something when we get a work item. A system notification once something is completed would be ideal, but only if it would appear on a dashboard or someplace the regulator user could view completion notifications, and maybe it could also be viewable by supervisors or AA (so that work can be done if the user is out of the office). I love the idea about viewable by supervisors! While I have great licensing people, we've had things come up from time to time where we have to cover for someone long term and unexpectedly. This would make it far easier for me as their supervisor to ensure things are getting covered. Noted.

38 #9 - State Regulator Review of Company/Branch Renewal (Exception Handling) Personas: Company Organization User (State) Ryan Company Control Person (Direct Owner) Sally Company Control Person (Branch Manager) Journey Map Sam Regulator Account Administrator (State) Fernando Regulator Organization User (State) Jessica Jessica - Regulator Organization User (State) (responsible for researching regulatory actions) Background:, a Company Organization User, has filed to renew his company and branch licenses from a state. The filing was based on the renewal requirements and fees previously established by the state's Account Administrator, Sam, in the state's regulator portal. The renewal also contains the control person filings for Ryan and Sally. The system performed a completeness check prior to allowing the filing to be submitted. The filing runs through regulator-defined rules/thresholds and any items that require additional review are flagged (in this case, a regulatory action against the company). Sam receives an Initial Review Task on his dashboard when the filing is received, and from his dashboard can assign review tasks to Fernando and Jessica. Tasks can be manually or automatically assigned based on configurable rules, or can be claimed by reviewers. Fernando and Jessica can access all information relevant to the filing from their review filing dashboard as they complete their review tasks. They complete their review checklists in the system, can place notes on the filing, and place action items if there are any deficiencies or they have questions to ask, Ryan, or Sally. After any action items are resolved and the review is complete, the filing is approved and the company and branch licenses are renewed. Human activity System activity Version 2, Delivered 3/16/17 BULK Option to perform action in bulk Preparation Review Outcome Preceding Journey(s) #17 - Regulator Account Administration #5 - State Renewals for Company/Branch License requirements and fees and defined rules/thresholds for flagged items established in #17 - Regulator Account Administration Secondary review by a regulator is optional and could be done by any individual with secondary approval privileges. Subsequent Journey(s) N/A , a Company Organization User, has filed to renew his company and branch licenses from a state. The filing was based on the renewal requirements and fees previously established by the state's Account Administrator, Sam, in the state's regulator portal. The filing also contains the control person filings for Ryan and Sally. The system performed a completeness check prior to allowing to submit, thereby ensuring that the state receives a complete renewal filing that meets all requirements. The filing runs through regulator-defined rules/ thresholds and any items that require additional review are flagged. In this case, a regulatory action against the company in the last year is a flagged item. For renewal, items that changed in the last year are also flagged (e.g. closing of a branch, new executive, etc.). Sam receives an Initial Review Task on his dashboard when the filing is received, and from his dashboard can assign review tasks. Tasks can be manually or automatically assigned based on configurable rules, or can be claimed by reviewers. Tasks can also be reassigned for specialization or workload balancing. Sam's dashboard displays all open tasks, assigned tasks, overdue tasks, metrics, etc. Sam creates a task for Jessica to review the details of the regulatory action, and another task for Fernando to review the rest of the filing. Fernando and Jessica access all information relevant to the filing from their review filing dashboard as they complete their review tasks (e.g. filing, attachments, regulatory actions, license history, notes from other regulators, etc.). This includes all information on the company, branch, and Control Persons. Fernando and Jessica complete their review checklists in the system, and place action items if there are any deficiencies or they need to ask, Ryan, or Sally any questions. They can also include internal notes, upload documents, set due dates for the action items, and their contact information is included with the action item., Ryan, and Sally receive a task to complete on their dashboard when an action item is placed. They are notified via , click a link in the taking them to the NMLS login page, log in, and are taken to the task. They resolve the action items by responding with additional information or uploading documents. Fernando and Jessica receive Follow-Up Review Tasks to complete when the specific action items that they placed are resolved. They complete the tasks and finalize their review. Fernando, tasked with conditionally approving or rejecting the filing, makes a determination. They can also place additional action items for, Ryan, or Sally if necessary. Sam receives a Final Review Task, where he does a secondary review of Fernando's decision, and either approves or denies the filing. He can also create a task for Fernando to obtain additional information. The system generates a notification for, Ryan, and Sally and other configured users at their company with the final decision. If approved, the company and branch licenses are officially renewed and the license record is updated in NMLS. User Experiences: I am able to configure and update the specific items and fees that are required to apply for a license in my state. The system performs a completeness check prior to allowing a licensee to submit a filing, ensuring that I receive a complete filing. I receive notification of items that have been flagged for additional review which allows me to prioritize my workload. Sam Sam Sam Sam If I have a question while I am reviewing the filing, I can access specific help resources right on the screen I am working on. Sam My streamlined and customized dashboard helps me stay organized by displaying my work items in a prioritized manner. Sam I am able to customize how tasks are assigned or claimed at my agency. Sam I can easily assign tasks via my dashboard and the system automatically assigns other tasks. Jessica Fernando The filing and relevant information is presented to me in an easy-to-use format. Jessica Fernando I can communicate with other users in the system to get the information I need. Jessica Fernando I am able to complete all steps of the filing review process within NMLS, including communicating with other users and downloading all documents. Sam I am able to send notifications to users in the system to keep them updated on the status of a task or outcome. I can easily identify who placed an action item and their contact information is displayed right in the task 37

39 #9 - State Regulator Review of Company/Branch Renewal (Exception Handling) NMLS 1.0 Pain Points: Varying state checklist requirements (which are external to the NMLS system) create confusion during the filing submission process. Regulators have to deal with incorrect interpretation of checklist items. The system allows licensees to submit filings that have missing or insufficient information. The review workflow is complex, not intuitive, and does not provide transparency into what items I need to review. Difficulty locating help resources on the Resource Center. The worklist is very confusing, does not allow a user to prioritize items, and contains items that don't even require action. Users are unable to customize the view of a worklist. The worklist doesn't provide an accurate picture of a user's true workload. No ability to mark items as resolved or clear them from the worklist. There is no easy way to assign tasks or send notifications or reminders. Users don't know how to prioritize their work. There is no easy way to sort and filter records. The filing often contains information that isn't required by a state, but the regulator has to review it anyways. Too many clicks required to view details of a work item, create license items, update license status, etc. Unable to communicate with other users in the system. When a regulator places an action item, the licensee has no idea who placed it or how to contact them. There is no ability to track changes to records or provide an audit trail of actions. There is no ability to place internal notes on a filing. There are a number of items and tasks that have to be performed outside of NMLS (e.g. submitting forms, paying invoices, etc.). Regulators often wait for items to be received outside of the system before they can review a filing. The sponsorship approval process is currently an additional step after the license has been approved. Applicants are unsure of the status of their application after submitting. The system does not provide licensing history. NMLS 2.0 Capabilities: Ability to include state agency requirements and allow state agencies to edit these requirements. Ability to set regulator fees and other configurable license requirement and workflow settings. Ability to dynamically require additional steps or uploaded document(s) based on pre-defined rules on fields such as license type and state. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to check submitted forms for completeness against requirements and provide immediate user feedback on gaps/errors/omissions. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability for regulators to control what steps individuals have access to. Ability to assign tasks to individuals/groups. Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to customize the view of the dashboard by task, industry, company, or other attribute. Ability to prioritize and assign workload. Ability for system to identify records that pass all regulator-defined checks with ability to single-click approve that population. Ability to configure auto-approval thresholds (e.g., credit checks, CBC, etc.). Ability to auto-assign certain tasks by state, work item type, etc. Ability to secure data downloaded from the system to protect PII and other sensitive data. Ability to show and access version history of uploaded documents. Ability to limit access to sensitive documents / data in the system by group / user. Ability to see other state regulator notes on credit report reviews (need to think through privacy concerns). Ability to track all actions, activities, and changes with an audit trail. Ability to send reminder notifications for pending/incomplete tasks. Ability to restrict some communications to regulator access only. Ability to set due dates. Ability to attach regulator/reviewer contact information to action items/communications. Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to download documents for review. Ability to communicate with other users within the system. Ability to ensure positive confirmation of what is being worked by the regulator (and who is working it, particularly where problems are identified). Ability to bulk upload data or bulk complete actions (multi-record select) in order to complete actions on multiple records at once (e.g., approve multiple licensees). Ability to send multiple notifications to different parties when actions are taken (e.g. license is approved) Ability to configure automatic approval (e.g., the ability to automatically approve a sponsorship with an approved license and employment relationship). Ability to provide insight into state regulator review progress. 38

40 NMLS 2.0 Journey Map Engagement Journey Map 9 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator The renewal journey map appears to only contemplate auto renewals. Are the system settings for renewals such that a regulator will still have the option to manually review certain license types? Also, is the journey of those renewal requests flagged and not being auto renewed captured in another map or is that too granular at this point? Yes. What system limitations exist for you to adopt auto renewal? Flagged for Future Response X 39

41 #10 - State Regulator Review of Individual Licensee Renewal Personas: Journey Map Company Organization User (State) Mary Individual Licensee (State) Sam Regulator Account Administrator (State) Background:, a Company Institution User, has filed to renew a license on behalf of Mary, an Individual Licensee. The filing was based on the renewal requirements and fees previously established by the state's Account Administrator, Sam, in the state's regulator portal. The system performed a completeness check prior to allowing the filings to be submitted. The filing runs through regulator-defined rules/thresholds and any items that require additional review are flagged (e.g. credit score, criminal history, company hasn't renewed yet, etc.). In Mary's case, there were no items in the filing that triggered any flags, resulting in a clean filing. Since the filing was complete, passed all checks required by the state, and is considered clean, the renewal is automatically approved by the system. and Mary receive a notification that Mary's license has been renewed. Mary's filing is archived in an autoapproved renewal section which Sam can access via his dashboard. Human activity System activity Version 2, Delivered 3/15/17 BULK Option to perform action in bulk Preparation Auto-Approve Post-Approval Preceding Journey(s) #17 - Regulator Account Administration #6 - State Renewals for an Individual Licensee Subsequent Journey(s) N/A , a Company Institution User, has filed to renew a license on behalf of Mary, an Individual Licensee. The filing was based on the renewal requirements and fees previously established by the state's Account Administrator, Sam, in the state's regulator portal. If or Mary did not want to renew the license, they have the option to surrender which is covered in journey map #20, or send the license to inactive if Mary wants to keep up her professional standards requirements. User Experiences: The system performed a completeness check prior to allowing Mary to submit, thereby ensuring that the state receives a complete filing that meets all renewal requirements. The filing runs through regulator-defined rules/ thresholds and, in Mary's case, there were no items in the filing that triggered any flags, resulting in a clean filing. Since the filing was complete, passed all checks required by the state, and is considered clean, the renewal is automatically approved by the system. Had Mary's filing been flagged based on the regulator-defined rules/ thresholds, it would enter a manual review process and flagged items would be pointed out to Sam. Sam and Mary receive a notification that Mary's license has been renewed. The notification includes reminders about important next steps, such as completing continuing education requirements. I am able to configure and update the specific items and fees that are required to apply for a license in my state. The system performs a completeness check prior to allowing a licensee to submit a filing, ensuring that I receive a complete filing. I receive notification of items that have been flagged for additional review which allows me to prioritize my workload. Sam Sam Sam Sam If I have a question while I am reviewing the filing, I can access specific help resources right on the screen I am working on. The system automatically approves the renewal based on the flags I set, meaning I have fewer filings to review and can focus on the more difficult ones. Sam Mary's filing is archived in an autoapproved renewal section which Sam can access via his dashboard. I am able to send notifications to users in the system to keep them updated on the status of a task or outcome. Sam I can configure the system to approve filings that meet certain criteria. Mary I receive a notification that my license was renewed. Sam My streamlined and customized dashboard helps me stay organized by displaying work items I need to take action on. Sam I am able to complete all steps of the filing review process within NMLS, including communicating with other users and downloading all documents. Sam The filing and relevant information is presented to me in an easy-to-use format. 40

42 #10 - State Regulator Review of Individual Licensee Renewal NMLS 2.0 Capabilities: NMLS 1.0 Pain Points: Varying state checklist requirements (which are external to the NMLS system) create confusion during the filing submission process. Regulators have to deal with incorrect interpretation of checklist items. The system allows licensees to submit filings that have missing or insufficient information. The review workflow is complex, not intuitive, and does not provide transparency into what items I need to review. Difficulty locating help resources on the Resource Center. There are a number of items and tasks that have to be performed outside of NMLS (e.g. submitting forms, paying invoices, etc.). Regulators often wait for items to be received outside of the system before they can review a filing. The filing often contains information that isn't required by a state, but the regulator has to review it anyways. Too many clicks required to view details of a work item, create license items, update license status, etc. Applicants are unsure of the status of their application after submitting. The worklist is very confusing, does not allow a user to prioritize items, and contains items that don't even require action. Users are unable to customize the view of a worklist. The worklist doesn't provide an accurate picture of a user's true workload. No ability to mark items as resolved or clear them from the worklist. There is no easy way to assign tasks or send notifications or reminders. There is no easy way to sort and filter records. Ability to include state agency requirements and allow state agencies to edit these requirements. Ability to set regulator fees and other configurable license requirement and workflow settings. Ability to dynamically require additional steps or uploaded document(s) based on pre-defined rules on fields such as license type and state. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to check submitted forms for completeness against requirements and provide immediate user feedback on gaps/errors/omissions. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to trigger reviews based on defined and configurable business rules (e.g., auto-approve clean renewals). Ability to configure automatic approval (e.g., the ability to automatically approve a renewal with a clean filing). Ability to download documents for review. Ability to communicate with other users within the system. Ability to ensure positive confirmation of what is being worked by the regulator (and who is working it, particularly where problems are identified). Ability for system to identify records that pass all regulator-defined checks with ability to approve that population. Ability to configure auto-approval thresholds (e.g., credit checks, CBC, etc.). Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to notify users via . Ability for regulators to control what steps individuals have access to. Ability to assign tasks to individuals/groups. Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to customize the view of the dashboard by task, industry, company, or other attribute. Ability to prioritize and assign workload. Ability to send multiple notifications to different parties when actions are taken (e.g. license is approved). 41

43 NMLS 2.0 Journey Map Engagement Journey Map 10 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Regulator 1: Map #10 = 1. We do not participate in auto renewal, so I would parrot the other Regulators on that item. What would the map look like for those who manually review credit and background each year? 2. Item 1 states they could surrender or move the license to inactive should they choose not to renew. Idaho requires that all inactive licensees submit renewal requests and maintain the renewal requirements. Perhaps I need a little more clarification on this action? 3. Item 5 it states that the individual would be notified once the renewal is approved of next steps "such as completing continuing education requirements." Are they referencing requirements for the next year? We would not renew a licensee who had not fully completed all requirements prior to renewal request. Yes. What system limitations exist for you to adopt auto renewal? Flagged for Future Response X Regulator 2: We currently do a manual review of all renewals. Our internal database requires us to go in and manually update the expiration date of the license. Currently I am trying to find a remedy to this situation. We are in a better position than we were, as we used to print individual mortgage loan originator licenses and mail them. 42

44 #12 - Federal Registration (Individual) Personas: Journey Map Matt Individual Registrant Kim Institutional Organization User (Federal) Version 2, Delivered 3/16/17 Background: An Institution Organization User (Kim) wishes to file for federal registration on behalf of one of her institution's individual registrants, Matt, as well as a number of other new hires at her company. The registrants' NMLS accounts were previously created and populated with the core data needed to register. In addition, they completed their fingerprinting for the CBC. Kim logs into her account to initiate the bulk filing, which she can complete utilizing either a bulk upload template, or an API which interfaces with her institution's internal systems to expose data. Once the filings are complete and Matt and the other registrants have attested, the federal registration fee is paid by Kim and the filings are submitted to the federal registry. Note: Employing institutions must obtain a credit report for new registrants outside of NMLS. Note: Registrants must update their registration each time they change federal employers. Human activity System activity BULK Option to perform action in bulk Preparation Submission Preceding Journey(s) #42 - Pre-Registration Requirements (Individual) #46 - Account Creation for Federally-Registered Institutions Subsequent Journey(s) N/A Kim logs into her own NMLS account and clicks a button on her dashboard to take her to the page where she manages individual registrants. Kim initiates a bulk filing for all of the new registrants. She can do this by either using a bulk upload template, or an API which interfaces with her internal systems. For example, Kim can populate and upload a file with all of her registrants' information, or if Kim's company uses an API, this would be leveraged to expose the employee list and allow Kim to pick which registrants to upload information and initiate filings for. The filing is automatically and completely populated by pulling information from Matt and the other registrants' records that were created during account set up. Example data includes address, date of birth, work history, disclosure questions, etc. If Matt or the others answered "Yes" to any disclosure questions, supporting documentation would be attached. Kim sends the filings to Matt and others to review, which creates a task on their dashboards. Matt reviews and notices an issue. Matt can make the change himself and attest, which sends a notification to Kim and creates a task on her dashboard. In this case, Matt sends the filing back to Kim to make the change, which creates a task on her dashboard. Kim then makes the change and sends back to Matt for review and attestation. User Experiences: Kim I am presented with error detail after uploading the bulk upload template, and have an opportunity to correct the errors and re-submit. I am able to complete all steps of the filing process within NMLS, including communicating with other users. BULK I am able to quickly and easily navigate throughout the different sections of the filing and the onscreen status bar keeps track of my progress. Federal institutions have the ability to upload individual filings in bulk utilizing a bulk upload template or an API which interfaces with my internal system. I can come back to the filing later and my information will be saved, even if I get timed out. The system pre-populates my filing by pulling information stored in my record. Kim Kim Kim Matt Kim I receive an notification The system performs a I can attest to my filing on my that a company has created a completeness check and I receive a notification that my mobile device, and can get to the filing that requires my notifies me of any missing filing was successfully attestation page from a link attestation. information before allowing submitted. found in the I receive. Matt Matt me to submit. Kim Kim Kim Kim BULK Matt reviews the updated filing and attests, and the other registrants attest as well. Kim receives a notification that they attested, pays the federal registration fees, and submits the filings. Kim has the ability to pay for filings in bulk. Kim's invoice payment screen shows all outstanding filings, and she can select which invoices to pay. CBC checks are also requested at the time of submission. BULK If I have a question while I am completing the filing, I can access specific help resources right on the screen I am working on. I can pay for my registrants' filings in bulk and select which filings to include in an invoice. 43

45 #12 - Federal Registration (Individual) NMLS 1.0 Pain Points: Registrants are often unsure of where to start in the registration process. Criminal Background Check process does not include fingerprint scheduling. When a federal institution is granted access by an individual, they receive a notification that they were granted access but it does not say who it was that granted access. The filing workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process. Difficulty locating help resources on the Resource Center. Unable to communicate with other users in the system. Federal institutions currently have to pay for individual registrants one at a time. Users do not receive confirmation that their filing has been successfully submitted. NMLS 2.0 Capabilities: Ability for companies to control what steps individuals have access to. Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to re-use background checks that are stored in a user's record. Ability to initiate tasks based on user actions, another user's actions (who created a task for you), or system generated activities. Ability to assign tasks to individuals/groups. duplication (e.g., streamlined, intuitive user interface). Ability to see progress while completing the filing (e.g., visually represent with a status bar where the user is in the overall filing workflow). Ability to bulk upload data (file upload) or bulk complete actions (multi-record select) in order to complete actions on multiple records at once (e.g., file for multiple registrants). Ability to request account access from an individual. Ability to leave and come back to a filing and resume in the same location (i.e., save and continue). Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to upload and tag documents with metadata in the document upload section based on workflow and context. Ability to communicate with other users within the system. Mobile capability for core licensing workflow functionality (smartphone, tablet). Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to make multiple payments in one invoice similar to a shopping cart concept. Users are able to withdraw a filing at any time in the process. Ability to send multiple notifications to different parties when actions are taken (e.g. registration is approved). 44

46 NMLS 2.0 Journey Map Engagement Journey Map 12 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Federal Registrants Fed Registration, Step 5 - I don't see why the MLO (employee) would make note of what needs to be changed on their MU4R and then require the bank's Administrator to make the change. Noted Flagged for Future Response If the employee is correcting data in the bank's file on them, then the onus needs to be on the employee to make the corrections... This seems to add additional work for the administrator and removes responsibility from the employee. Federal Registrants Submission >#5: Will each institution user have their own dashboard or will there be a "Community" dashboard? I.e. When MLO attest tp the MU4R and submission is required, will all institution users see this on a "community" dashboard, or will notification appear on an individual user's dashboard? If individual, who (i.e. user that creater MU4R, designated inst. user set up tp review MU4Rs? The institutioal user will have a dashboard that will reflect task and acvities associated with their MLOs/registrants. Each individaul will also have their own dashboard. Federal Registrants Submission >#5; Could post-registration changes be batch-uploaded to NMLS? Will need to investigate. X 45

47 #13 - Federal Renewal (Institution) Personas: Journey Map Kim Institutional Organization User (Federal) Background: Kim, an Institution Organization User (Federal), wishes to renew the federal registration for her institution, a process completed annually. Kim has previously been assigned permission to renew the institution's filing. Kim clicks on the renewal section on her dashboard which activates at the start of each renewal season to initiate the renewal. Kim is guided through a process to determine if anything has changed since last year, making any updates as necessary. Once the filing is complete, Kim pays the federal renewal fee, and the renewal is submitted to the federal registry. Note: This journey also applies to late renewal, which is the same process as renewing a registration, but occurs after the renewal deadline has passed. Late renewal also requires the payment of a late fee. Note: Institutions that have been acquired or merged into another company prior to renewal need to terminate their registration. Human activity System activity Version 2, Delivered 3/16/17 BULK Option to perform action in bulk Preparation Submission Preceding Journey(s) Subsequent Journey(s) #11 - Federal Registration (Institution) N/A Kim wants to renew the federal registration for her institution and clicks on the renewal section on her dashboard which activates at the start of each renewal season. The system walks Kim through a guided process to determine if anything has changed on the institution's record since the last filing. Kim makes any updates as necessary. The core data for the renewal filings is automatically populated by pulling information from the institution's record and prior filing. Kim reviews the renewal to ensure accuracy, pays the federal registration fee, and submits to the federal registry. Kim receives a notification that the registration was renewed, and the notification contains reminders for next steps (e.g. annual renewal). Kim is also prompted to ask if she wants to pay other outstanding invoices for her institution or individual registrants. User Experiences: Kim Kim The system performs a completeness check and notifies me of any missing information before allowing me to submit. I receive a notification that my renewal was successfully submitted. Kim Kim I am able to quickly and easily navigate throughout the different sections of the renewal and the onscreen status bar keeps track of my progress. I am able to complete all steps of the filing process within NMLS, including communicating with other users and uploading/submitting all documents. Kim Kim I can come back to the filing later and my information will be saved, even if I get timed out. If I have a question while I am completing the filing, I can access specific help resources right on the screen I am working on. Kim Kim The system pre-populates my renewal filing by pulling information stored in the institution's record. I am able to delegate renewal activities to members of my staff. Kim When renewing my institution's registration, the system provides me with a streamlined process to renew. 46

48 #13 - Federal Renewal (Institution) NMLS 2.0 Capabilities: NMLS 1.0 Pain Points: Registrants are often unsure of where to start in the registration process. The filing workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process. Difficulty locating help resources on the Resource Center. Unable to communicate with other users in the system. Users do not receive confirmation that their filing has been successfully submitted. Ability for users to assign roles and permissions. Ability to initiate tasks based on user actions, another user's actions (who created a task for you), or system generated activities. Ability to assign tasks to individuals/groups. Ability for companies to control what steps individuals have access to. Ability to have role-based security access. Ability to combine logical workflow components to facilitate the user experience and reduce Ability to see progress while completing the filing (e.g., visually represent with a status bar where the user is in the overall filing workflow). Ability to leave and come back to a filing and resume in the same location (i.e., save and continue). Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to upload and tag documents with metadata in the document upload section based on workflow and context. Ability to communicate with other users within the system. Mobile capability for core licensing workflow functionality (smartphone, tablet). Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to make multiple payments in one invoice similar to a shopping cart concept. Ability to send multiple notifications to different parties when actions are taken (e.g. renewal is submitted). 47

49 NMLS 2.0 Journey Map Engagement Journey Map 13 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Federal Registrants Federal Registrants Map #13 -I think this needs to consider what my actually be the first step in the renewal process - obtaining a PDF copy of the last filing that is then circulated amongst the various areas of the institution that may need to weigh-in on what edits may be required. Allow renewal and payment of the institution prior to 11/1. Noted. Thank you. Flagged for Future Response 48

50 #14 - Federal Renewal (Individual) Personas: Journey Map Matt Individual Registrant Kim Institution Organization User (Federal) Background: In order for an individual registrant (Matt) to maintain an active federal registration, the registration must be renewed each year by his institution in advance of the NMLS deadline (12/31). An Institution Organization User (Kim) is responsible for filing for renewal on behalf of Matt. Working at a large institution with responsibility for renewing many registrants, Kim performs all renewal activities in bulk. Kim clicks on the renewal section on her dashboard which activates at the start of each renewal season to go to the renewal page. From here, she can initiate and submit renewals for her registrants and pay the renewal fees. Kim leverages the API gateway to ensure all of her registrants' information is up-to-date in NMLS before initiating the renewals, which also helps to avoid overpaying for registrants who do not end up renewing. The registrants, including Matt, receive a task to review and attest to the filing, and make any changes as necessary. Once they attest, the registration is officially renewed. Note: This journey also applies to late renewal, which is the same process as renewing a registration but occurs after the renewal deadline has passed. Late renewal also requires the payment of a late fee. Note: Institutions must renew prior to submitting renewals for individual registrants. Human activity System activity Version 2, Delivered 3/16/17 BULK Option to perform action in bulk Preparation Submission Preceding Journey(s) Subsequent Journey(s) #12 - Federal Registration (Individual) N/A Kim wants to renew the federal registration for her registrants and section on her dashboard which activates at the start of each renewal season. Kim initiates a bulk renewal for all of the registrants and pays the renewal fees. Prior to initiating the renewal, Kim leverages the API gateway to ensure all of her registrants' information is up-to-date in NMLS, including employee status, which also helps to avoid overpaying for registrants who do not end up renewing. If there are any discrepancies between the internal system and NMLS, the data is corrected prior to initiating the renewal. The filing is automatically and completely populated by pulling information from Matt and the other registrants' records. Example data includes address, date of birth, work history, disclosure questions, etc. If Matt or the others answered "Yes" to any disclosure questions, supporting documentation would be attached. Matt and the other registrants receive a task when a renewal is initiated on their behalf, and log into the system to review. Matt reviews and makes any updates as necessary. Kim receives a task if Matt makes any changes, and does a final review before submitting. If Matt and others attest without changes, their registrations are officially renewed. User Experiences: Kim Kim When filing for federal renewal, the system provides me with a streamlined process to renew. I am able to complete all steps of the filing process within NMLS, including communicating with other users and uploading/ submitting all documents. I am able to quickly and easily navigate throughout the different sections of the filing and the onscreen status bar keeps track of my progress. I receive an notification that an institution has created a filing on my behalf that requires my attestation. Federal institutions have the ability to upload individual filings in bulk utilizing a bulk upload template or an API gateway which interfaces with my internal system. Kim Kim Kim Matt Matt BULK I can attest to my filing on my mobile device, and can get to the attestation page from a link found in the I receive. Kim I can come back to the filing later and my information will be saved, even if I get timed out. The system performs a completeness check and notifies me of any missing information before allowing me to submit. Kim Kim Matt I can leverage an API gateway to ensure my registrants' information is up-to-date throughout the year. I receive a notification that my application was successfully submitted. The system pre-populates my filing by pulling information stored in my record. Kim Kim Kim If I have a question while I am completing the filing, I can access specific help resources right on the screen I am working on. I can pay for my registrants' filings in bulk and can pick and choose which filings to include in an invoice. I can configure the system to be the default payer for all of my registrants' activities in NMLS. 49

51 #14 - Federal Renewal (Individual) NMLS 2.0 Capabilities: NMLS 1.0 Pain Points: Registrants are often unsure of where to start in the registration process. The filing workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process. Difficulty locating help resources on the Resource Center. Unable to communicate with other users in the system. Federal institutions currently have to pay for individual registrants one at a time. Companies often overpay for registrants who do not end up renewing. Users do not receive confirmation that their filing has been successfully submitted. Ability for companies to control what steps individuals have access to. Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to see progress while completing the filing (e.g., visually represent with a status bar where the user is in the overall filing workflow). Ability to bulk upload data (file upload) or bulk complete actions (multi-record select) in order to complete actions on multiple records at once (e.g., file for multiple registrants). Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to upload and tag documents with metadata in the document upload section based on workflow and context. Ability to communicate with other users within the system. Mobile capability for core licensing workflow functionality (smartphone, tablet). Ability to initiate tasks based on user actions, another user's actions (who created a task for you), or system generated activities. Ability to assign tasks to individuals/groups. Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to make multiple payments in one invoice similar to a shopping cart concept. Ability to send multiple notifications to different parties when actions are taken (e.g. renewal is submitted). 50

52 NMLS 2.0 Journey Map Engagement Journey Map 14 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Federal Registrants Preparation >#2; Would NMLS have an option for Leave of absense? Temporarily inactive? This came up during our discussions with institution in January. We'll need to investigage as part of our update to statuses. Flagged for Future Response X 51

53 #15 - Account Creation by Company Account Administrator (for State-Licensed Companies) Personas: Journey Map Jim Company Account Administrator (State) Company Organization User (State) Ryan Company Control Person (Direct Owner) Sally Company Control Person (Branch Manager) Mary Individual Licensee (State) Will SRR Entitlement User Background: Jim, a Company Account Administrator (State), is responsible for his company's licensing activities, which means ensuring his company, branch, and licensees maintain licensure and comply with all state regulations. As the company is newly established, they have not used NMLS to file for any licenses. Jim previously visited the state agency's website to find out how to apply for a license, and was directed to the NMLS website to find the instructions on how to request a new account. After creating an account, Jim will be able to begin all of the necessary licensing activities, such as creating the company and branch records, creating accounts for other users, and assigning roles and permissions. Note: Company and branch record creation are explained in more detail in journey #38 - Company / Branch Setup. Note: Some individuals will be seeking both state licensure and federal registration. Note: State agencies want to be able to manage a registration process on NMLS. The difference between licensure and registration is fewer requirements and automatic approval by state agency. Human activity System activity BULK Option to perform action in bulk Account Setup User Setup Next Steps Record Creation Jim previously visited the state agency's website to find out how to apply for a license, and was directed to the NMLS website to find a clearly defined set of 'quick links' which includes setting up a new account. Jim Jim Preceding Journey(s) N/A Jim selects the initial account type he wants to register for, in this case Company Account Administrator, and is asked if this is for a new company in NMLS. Jim is prompted to input basic information about himself and his company (e.g. SSN and EIN) for validation. User Experiences: I am provided with a clearly defined set of 'quick links' which includes setting up a new account. The system walks me through the process of entering core data and uploading required documents into the document repository. The system validates Jim and the company's basic identifying information against external data sources and against rules to prevent duplication (e.g. duplicate addresses). If there are no issues, then Jim's account and the new company (if applicable) record are created. If there are any issues or red flags, the request goes to SRR for manual review (Will). Jim Jim Jim receives a login and password in his and logs into NMLS for the first time. He changes his password, sets security questions for self-service password reset, and includes a personal address for account recovery. Jim Jim Jim is presented with an option to create accounts for other company users, including, Ryan, Sally, and Mary. Jim enters basic identifying information about each user, including SSN, which is validated against external data sources and against rules to prevent duplication (e.g. duplicate addresses). Jim also assigns users to roles (e.g. org user, control person, licensee) and tailors permissions as needed. Jim confirms that the company will be sponsoring Mary's license. Jim Jim, Ryan, Sally, and Mary receive a login and password in their and log into NMLS for the first time. They change their passwords, set security questions for self-service password reset, and include a personal address for account recovery. After completing the account set up, Ryan, Sally, and Mary are presented with options regarding what they would like to do next. BULK A complete list of all the information I need to create an account is included right on the screen. The system performs a completeness check and notifies me of any missing information before allowing me to complete the records. Jim completes his own personal profile information such as address, phone number, etc. If I have a question while I am creating an account, I can access specific help resources right on the screen I am working on. The core data and documents become part of the company and branch records and are available to use across multiple filings / licenses. Individuals who are licensed, or have an intent to become licensed, will be assigned an NMLS ID at account creation. The system automatically validates the information that I enter for myself and company, such as SSN and EIN. I am able to establish accounts and set roles and permissions for my company's users during the account creation Mary The single login gives Jim the ability to establish and manage all related company, branch, and individual records. Ryan Sally, Ryan, Sally, and Mary complete personal profile information such as address, phone number, etc.. They also approve the employer previously assigned by Jim. I am automatically notified when my account is created in NMLS. Mary Jim Ryan The system cross-references data to ensure consistency across records. #1 - Pre-Licensure Requirements (Individual State Licensee) #37 - Pre-Licensure Requirements (Control Person) #38 - Company / Branch Setup Ryan and Sally select the option to complete prelicensure requirements for owners/branch managers, and Mary selects the option to apply for a license. A guided process begins to walk them through next steps, which are covered in subsequent journeys #37 and #1. Sally I can change my password without having to call the contact center. Subsequent Journey(s) ?? Jim is then presented with an option to create company and branch records, and the system walks him through a guided process. Mary Ryan Sally Jim creates the company and branch records, enters all core data that will automatically be prepopulated into state filings later, and uploads relevant documents that will be needed (see journey #38 - Company / Branch Setup). Personal profile information will be automatically prepopulated into state filings later. 52

54 #15 - Account Creation by Company Account Administrator (for State-Licensed Companies) NMLS 1.0 Pain Points: Difficulty locating help resources on the Resource Center. The account request process is currently done outside of the system through the call center. The system doesn't validate if a user already has an account, leading to the creation of duplicate accounts. Profile information is not validated against third party data sources. addresses are not validated and sometimes users will enter an incorrect address. Individuals without a SSN have challenges receiving an NMLS ID. Users have to maintain multiple logins and passwords to manage the various entities they are affiliated to. Sole proprietors are required to have separate logins for their company and for themselves. Users spend too much time logging in and out of the system to manage various entities. The system is not validating legal entities, but simply checking if the EIN exists or not. There is no ability to auto-fill filings which leads to entering data that is already in the system. There is an insufficient level of granularity when it comes to existing permissions. Users often don't know what exactly they are granting access to when providing access to another user. Users are able to complete certain actions that their company may not want them to complete. NMLS 2.0 Capabilities: Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to easily toggle between one entity and another for which the user has an admin or organization role. Ability to attach personal details to personal profile, such that changing companies does not invalidate certain personal details (e.g. valid fingerprints) Ability to integrate with third party data sources during data entry/upload to validate data (SSN, EIN, addresses, etc.). Ability to have a single login/profile, with access and association to multiple entities. Ability to suggest properly formatted addresses upon received error (any bulk uploads / API integrations). Ability to validate that addresses are consistent across filings. Ability to indicate what fields are required prior to entry and after form submission (if required fields were omitted). Ability to check submitted forms for completeness against requirements and provide immediate user feedback on gaps/errors/omissions. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability for company admins to set aliases for entity names that would be used alongside legal names. Ability to store company documents in a central location. Ability to have role-based security access. Ability for users to assign roles and permissions. Ability for companies to control what steps individuals have access to. Ability to notify users via . (e.g., NMLS login credentials). Ability to send multiple notifications to different parties when actions are taken (e.g. account is created). Ability to reset password without calling the Contact Service Center. Ability to perform file validations on uploaded files. Ability to tag documents with metadata in the document upload section based on workflow and context. Ability to upload multiple files at one time. Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. 53

55 NMLS 2.0 Journey Map Engagement Journey Map 15 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Step 8: Allow administrators to input data, allow Recommendations will be noted and will be employment to fill from sponsorship so matches considered during requirements. We will look to exactly. allow administrators to complete as much of the Step 10: Administrators should be able to select account creation process on behalf of their users as licenses and pre-licensure items. we can. Step 6: Administrator should be able to select license without answering a serious of questions if they know which license is required; there are many factors as to which license(s) are required/or not required. Control people like to just review and attest; Administrator should be able to complete all data input, e.g. updating pending litigation, etc. All state agency requirements identified in system, without requiring outside items to be sent for applications and renewals will be a big help. Common theme: Our administrators complete all the input, select licenses, pay for all items including prelicensing, tests, applications, invoices, renewals, etc. so administrators should have the ability to do so, if the company prefers this option. Flagged for Future Response Industry Step 8: Can complete the personal information entry for Sally, Ryan, and Mary? At larger companies, the Account Administrator may have the task of completing everything required for individuals other than the review and attestation. has the ability to complete the personal information entry (as depicted in Step #TBD). X Regulator Regulator Is it possible to do an address check to make sure there are not multiple companies/branches at the same location? When establishing account administrators, will there be an attestation or checkbox where the individual must acknowledge that they are an employee of the entity (helps to prevent third parties from being account administrators). Address validation will be a part of entity creation. Yes, as well as system constraints that should prevent an admin role to be provided to a third party user. Regulator Does the external data verification in Step 3 mean the EIN # and SS# could potentially be verified from government sources, not just verified they don't exist in NMLS? If so, would there be any notification to regulators if incorrect data was entered (beyond obvious typos)? Yes - verification would ensure that the entered information belongs together and authentication would ensure that the data entered is owned by the individual entering the information. We can explore flagging accounts for regulators where areas of concern were identified. 54

56 NMLS 2.0 Journey Map Engagement Journey Map 15 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Step 5 ends with a statement about Jim indicating he will be sponsoring Mary's license. Maybe because this is so high level, but this seems odd since there is no individual license indicated yet. Same for Step #7, the individuals approve the employer previously assigned - there hasn't been a reference to this in the previous steps so not sure where Jim assigns this, and (5) Step 6 talks about the individuals listing a personal address. Is this going to be readily available to regulators as well as the on the application? Noted. We will clarify the process flow. Flagged for Future Response 55

57 #16 - Company / Institution Account Administration Personas: Jim Company Account Administrator (State) Sophie Company Account Administrator (State) Journey Map Mary Individual Licensee Background: This journey demonstrates the capabilities that are available to a Company/Institution Account Administrator in NMLS 2.0 in order to manage an entity's accounts and licensing/registration activities. This journey does not follow a typical linear progression of activities, but instead represents a collection of capabilities. Key capabilities include utilizing a dashboard to manage employees/entities, interfacing with internal systems to validate employee information, communicating with other users in the system, assigning roles/permissions, managing notifications, enabling/disabling/unlocking accounts, designating additional Account Administrators, and setting company aliases. Human activity System activity API API Gateway Version 3, Delivered 3/30/17 BULK Option to perform action in bulk Dashboard Roles / Permissions Interface with Internal Systems Notifications Entitlement Create Administrator Entity Aliases Preceding Journey(s) #15 - Account Creation by Company Account Administrator (for State-Licensed Companies) A guided wizard will assist users with selecting the right account type to create. Subsequent Journey(s) N/A Jim logs into NMLS and is taken to his Account Administrator dashboard. From this one centralized dashboard, Jim can toggle back and forth between entities, access all of his company and branch records and licensee/registrant/ other organization user accounts, assign tasks, send notifications, and perform all tasks related to licensing/ registration. Jim's company recently hired a few new employees who do not have NMLS accounts. Jim clicks the button to create accounts and enters the required information. See #15 - Account Creation by CAA (for State- Licensed Companies) and #46 - Account Creation for Federally-Registered Institutions for more details on account creation. Bulk User Experiences: Jim assigns each of these new employees to a specific role (e.g. licensee, owner, branch manager) which gives them the applicable permissions for that role that Jim previously configured. Jim is responsible for ensuring his licensee's profile information in NMLS matches the information in the company's HR system. Jim leverages his company's API gateway which interfaces NMLS with his HR system on a monthly basis to perform a reconciliation. The system compares the data and Jim is presented with a list of differences to decide which version to apply to NMLS (keep/ overwrite). API Jim notices that Mary has some discrepancies, and needs to ask her for clarification. Jim assigns Mary a task to review the discrepancies and let him know what is the correct version. Jim decides that he wants to start sending quarterly reminders to his licensees to complete their continuing education requirements and clicks on the notifications link from his dashboard. Federal AA's could send reminders to individual registrants to verify their personal information prior to renewals. Jim is responsible for account entitlement issues within his company, such as unlocking, enabling, and disabling accounts. Jim receives two tasks on his dashboard. One company user entered their password incorrectly too many times and is locked out of their account. Another company user is on leave, and Jim needs to temporarily disable their account to restrict online access. Jim's company is required to have two Account Administrators by the system From his dashboard, Jim clicks the button to create accounts and sets up an account for Sophie, another Account Administrator. The system validates Sophie's basic identifying information against external data sources and against rules to prevent duplication (e.g. duplicate addresses). Jim assigns her the same permissions that he has for himself. Alternatively, Jim could send a request out to Sophie's address to create her own account. Jim's company has several affiliated entities with similar names. Jim decides that it would be easier to manage the affiliates within NMLS if they were assigned aliases that were easier to differentiate. I am able to manage accounts and licensing/registration activities for all of the entities I am affiliated with from one centralized dashboard. I am able to configure role-based security access and permissions for each of my company users. Jim Jim Jim Bulk I can set aliases for entity names that would be used alongside legal names to make it easier to differentiate the entities. Jim I can interface NMLS with internal systems such as HR systems to validate that all of my company users' information in NMLS is accurate and upto-date. Jim The system automatically compares the data from my internal system to NMLS and provides me with the ability to make any corrections. Jim clicks the link to view all of the entities he has access to, and from there is able to enter aliases for each affiliate. The aliases do not supersede or correlate to OTNs, as this is simply a usability feature. I am able to initiate and assign tasks to users to complete certain actions. I can configure the system to send notifications to certain user groups within NMLS. My company users are able to reset their passwords themselves, but I can help them if they get locked out of their accounts. Jim Jim Jim Jim I can easily add additional Account Administrators right in the system. 56

58 #16 - Company / Institution Account Administration NMLS 1.0 Pain Points: The administration page requires too many clicks and searches are not user friendly. Difficult to see a compiled list of record information without clicking on every link on the left navigation panel. Composite View terminology is hard to comprehend (no one knows what this means). Too many issues with account/password reset. There is no overall view to delete users from the system, multiple clicks and manual data entry required to delete multiple users. Security questions for passwords should be a dropdown rather than a field to allow user to make own questions. Lack of clarity on how dormant accounts are managed (e.g. purges or cleared of sensitive information?) Many manual processes are needed to complete routine tasks Challenges with communications and sharing of documents outside the system Need to access internal systems as well as NMLS to complete simple tasks Unable to view a list of all of individuals associated to a company (company has to search for each individual separately.) Inability to interface with internal systems There is an insufficient level of granularity when it comes to existing permissions Changes to a company account are not reflected at the control persons level (no ripple effect). Users often don't know what exactly they are granting access to when providing access to another user. Process to add/delete Account Administrators is difficult. Difficult to locate help resources on the Resource Center No way to communicate with other users within the system NMLS 2.0 Capabilities: Ability to configure if company or individual is primary payer (need to determine if this is a company or individual choice) Ability for users to assign roles and permissions Ability to recover account through self-service and multiple means Ability to upload data files from company HR systems to perform a validation against data in NMLS (reconciliation between HR systems and employees' NMLS records). Includes workflow and processing to compare uploaded data to NMLS data and provide a screen to decide which version to apply to NMLS (keep/overwrite). Ability to view/generate a full or object-level audit trail (e.g. list of changes made to a company license record) Ability to have an administrator grant another person administrative rights without having a fax in or a form Ability to filter data in reports and list views Ability to sort data in reports and list views Ability to communicate with other users within the system Ability to publicly (within NMLS, not consumer access) notate the reason why a change was made and capture free form notes to further describe the nature of the change. Ability to delegate / grant others the ability to unlock accounts Ability to have a single login/profile, with access and association to multiple entities. And the ability to identify and change what entity you are working on currently and all entities that you have access to in the system. Ability to extract data from NMLS in usable formats (e.g., CSV, delimited., etc.) Ability to reset password without calling the Contact Service Center Ability for company admins to set aliases for entity names that would be used alongside legal names. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to allow PII to be viewed at various levels of masking depending on the rights/relationships Ability to easily toggle between one entity and another for which the user has an admin or organization role. Ability to interface NMLS with internal systems such as Human Resource systems, GL, Testing, Accounting, and Education Ability to have role-based security access Ability to customize the view of the dashboard by task, industry, company, other Ability to limit access to sensitive documents / data in the system by group / user Ability for employers to manage an internal employee status (active / inactive, e.g. for military or other roles). Ability to initiate tasks based on user actions, another user's actions (who create a task for you), or system generated activities Ability to function as a real-time system where changes are reflected throughout the application immediately. Ability to remove access to legal entities after leaving an entity either from termination or change in employment Ability to assign tasks to individuals/groups Ability to configure who gets which notifications Ability to configure the delivery mode for notifications (e.g., , phone, etc.) Ability to search data within the system on specific screens and potentially with general search (including notes fields is nice to have) 57

59 NMLS 2.0 Journey Map Engagement Journey Map 16 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Questions for Journey Map #16, Step 5 1. How are licensees notified of tasks? a. If notifications are delivered by , are they standard language? b. Ability to customize and add free form text? 2. If API Gateway isn t leveraged, how are institutions made aware of discrepancies? 1. Most likely through a system dashboard. A. notifications of tasks should also be an option. B. We can consider this option 2. Through internal system notifications and tasks. Plan is to allow the system to process those without issue and allow admins to make corrections and resubmit only those that were not initially processed. Flagged for Future Response Federal Registrant #16 Company/Institution Account Administration: Step 2 Reference made to Map #46 for Federal. Is that map available for review? Interface to internal systems Step 4 and 5 oneed more information about the company API file. Is the expectation to send a full data dump of all info daily? We have 25,000+ registered individuals. owill we be able to submit transactions for new hires, amendments and terminations? omonthly recon process Love the idea! Would like the flexibility to determine frequency at the institution level owe would also like the ability to submit changes as they occur. For example, John Smith changes his address in HR system. Change of address feeds to NMLS to update. Preferably, no action needed by John Smith. If my company will not allow, then change creates NMLS amendment and system s John to log in and attest to the change. Create Administrator Step 10 - We need ability to have more than 2 administrators. The API specifics are still under development, but your questions and needs will be shared with that group.

60 #17 - Regulator Account Administration and Portal Configuration Personas: Journey Map Sam Regulator Account Administrator (State) Background: This journey demonstrates the capabilities that are available to a Regulator Account Administrator in NMLS 2.0 in order to manage all of their agency's accounts and license fees and settings. This journey does not follow a typical linear progression of activities, but instead represents a collection of capabilities. Key capabilities include utilizing a dashboard to manage employees/agency activities, setting up an organization structure, establishing/ maintaining license and renewal fees and settings, configuring rules/thresholds for flagging review items, configuring auto-approval of filings/renewals, configuring task assignment, assigning roles/permissions, managing notifications, enabling/disabling/unlocking accounts, and designating additional Account Administrators. Michelle Regulator Account Administrator (State) Human activity System activity Version 4, Delivered 5/4/17 BULK Option to perform action in bulk Dashboard Department Setup License Fees and Settings Rules/Thresholds for Flagged Items Auto-Approval Configuration Roles/Permissions Task Assignment Notifications Entitlement Create Administrator Preceding Journey(s) N/A Sam can choose to notify his staff of any changes he makes in the regulator portal, and changes will be reflected in the system on the effective date. A guided wizard will assist users with selecting the right account type to create Subsequent Journey(s) N/A Sam logs into NMLS and is taken to his Account Administrator dashboard. From this one centralized dashboard, Sam can toggle back and forth between state departments, access all of his agency records and organization user accounts, assign tasks, send notifications, and perform all tasks related to licensing and examinations. Sam establishes the agency's organization structure, setting up each of the departments / divisions that his agency has and configuring what tasks / license types each will be responsible for. User Experiences: Sam wishes to configure the license and renewal fees and settings for his state. The settings include all of the requirements needed for applying for a company, branch, or individual license, such as required information, documents, professional standards requirements, control person attestations, etc. Sam clicks a button from his dashboard and enters the regulator portal, where he configures the fees and settings for each license type. Changes must be effective dated at least one day in the future, and will require SRR review. I am able to manage accounts and license filing review activities for all of the entities I am affiliated with from one centralized dashboard. While still in the regulator portal, Sam wishes to configure the rules/ thresholds for flagging items for review within filings. Sam selects the data attributes that he would like to configure rules/ thresholds for. For instance, Sam would like any criminal activity on the CBC to be flagged for additional review. Sam also wants to configure auto-approval for filings and renewals within the regulator portal. Sam selects from possible review options such as manual, flagging items based on rules/ thresholds with ability to single click approve, or fully automated approval. I am able to configure and update the specific requirements and fees needed to apply for a license in my state. Sam's agency recently hired a few new employees who do not have NMLS accounts. Sam clicks the button to create accounts and enters the required information. See #39 - Account Creation (Regulator) for more details on account creation. Sam assigns each of these new employees to a specific role (e.g. general reviewer, specialist, examiner) which gives them the applicable permissions for that role that Sam previously configured. Sam wishes to configure how tasks are assigned within his agency. From his dashboard, Sam clicks a link to go to task configuration. I can configure the rules/thresholds for flagging items for review within filings. Sam chooses the option he would like. Tasks can be manually assigned by an Account Administrator, automatically assigned based on configurable rules, or can be claimed by reviewers. Sam Sam Sam Sam BULK Sam decides that he wants to start sending monthly reminders to all license holders in his state to complete their continuing education requirements in advance of renewal season, and clicks on the notifications link from his dashboard. Sam creates a new notification, enters the text, sets the frequency, and chooses the user groups that will receive the notifications. The system will automatically send statebranded notifications moving forward. The system can be configured to automatically approve filings and renewals based on the rules I set, meaning I have fewer filings to review and can focus on the more difficult ones. Sam is responsible for account entitlement issues within his agency, such as unlocking, enabling, and disabling accounts. Sam Sam receives two tasks on his dashboard. One agency user entered their password incorrectly too many times and is locked out of their account. Another agency user is on leave, and Sam needs to temporarily disable their account. Sam's agency just hired an additional Account Administrat or, Michelle, and Sam is responsible for creating her account. I am able to configure role-based security access and permissions for each of my agency users. From his dashboard, Sam clicks the button to create accounts and sets up an account for Michelle. The system validates Michelle's basic identifying information against external data sources and against rules to prevent duplication (e.g. duplicate addresses). Sam assigns her the same permissions that he has for himself. Alternatively, Sam could send a request out to Michelle's address to create her own account. I am able to customize how tasks are assigned or claimed at my agency. I can configure the system to send notifications to certain user groups within NMLS. My agency users are able to reset their passwords themselves, but I can help them if they get locked out of their accounts. Sam Sam Sam Sam I can easily add additional Account Administrators right in the system. 59

61 #17 - Regulator Account Administration and Portal Configuration NMLS 1.0 Pain Points: The administration page requires too many clicks and searches are not user friendly. Difficult to see a compiled list of record information without clicking on every link on the left navigation panel. Composite View terminology is hard to comprehend (no one knows what this means). Too many issues with account/password reset. Security questions for passwords should be a dropdown rather than a field to allow user to make own questions. Lack of clarity on how dormant accounts are managed (e.g. purges or cleared of sensitive information?) There is no overall view to delete users from the system, multiple clicks and manual data entry required to delete multiple users. Varying state checklist requirements (which are external to the NMLS system) create confusion during the application submission process. Regulators don't have the ability to configure license settings and fees within NMLS. LSFS is built and managed in Salesforce instead of NMLS. Many manual processes are needed to complete routine tasks. Challenges with communications and sharing of documents outside the system. Need to access internal systems as well as NMLS to complete simple tasks. Unable to view a list of all of individuals associated to an agency (agency has to search for each individual separately.) Inability to interface with internal systems. There is an insufficient level of granularity when it comes to existing permissions. Users often don't know what exactly they are granting access to when providing access to another user. Process to add/delete Account Administrators is difficult. Difficult to locate help resources on the Resource Center. No way to communicate with other users within the system. NMLS 2.0 Capabilities: Ability for users to assign roles and permissions. Ability to recover account through self-service and multiple means. Ability to function as a real-time system where changes are reflected throughout the application immediately. Ability to remove access to legal entities after leaving an entity either from termination or change in employment. Ability to assign tasks to individuals/groups. Ability to configure who gets which notifications. Ability to configure the delivery mode for notifications (e.g., , phone, etc.). Ability to search data within the system on specific screens and potentially with general search (including notes fields is nice to have) Ability to have a single login/profile, with access and association to multiple entities. And the ability to identify and change what entity you are working on currently and all entities that you have access to in the system. Ability to restrict some communications to regulator access only. Ability to attach regulator/reviewer contact information to license items/communications. Ability to filter data in reports and list views. Ability to sort data in reports and list views. Ability to communicate with other users within the system. Ability to view/generate a full or object-level audit trail (e.g. list of changes made to a company license record). Ability to have an administrator grant another person administrative rights without having a fax in or a form. Ability to set regulator fees and other configurable license requirement and workflow settings. Workflow will require all changes to go through SRR review prior to going into effect. Ability to publicly (within NMLS, not consumer access) notate the reason why a change was made and capture free form notes to further describe the nature of the change. Ability to delegate / grant others the ability to unlock accounts. Ability to dynamically require additional steps or uploaded document(s) based on pre-defined rules on fields such as license type and state Ability to extract data from NMLS in usable formats (e.g., CSV, delimited., etc.) Ability to reset password without calling the Contact Service Center. Ability for system to identify records that pass all regulator-defined checks with ability to single-click approve that population. Also, ability to configure automatic approval for that population. Applicable to licenses, sponsorships, changes, renewals. Ability to configure auto-approval thresholds (e.g., credit checks, CBC, etc.) Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to allow PII to be viewed at various levels of masking depending on the rights/relationships. Ability to easily toggle between one entity and another for which the user has an admin or organization role. Ability to interface NMLS with internal systems such as state-licensing systems. Ability to have role-based security access. Ability to customize the view of the dashboard by task, industry, company, other. Ability to limit access to sensitive documents / data in the system by group / user. Ability to initiate tasks based on user actions, another user's actions (who create a task for you), or system generated activities Ability to trigger reviews based on defined and configurable business rules (e.g., If a new MLO, review record before submitting or if existing MLO, and low risk, possibly automate). Ability to configure by states when certain items need to be reviewed during renewals such as credit checks, CBC, and finger prints needing to be renewed. 60

62 NMLS 2.0 Journey Map Engagement Journey Map 17 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Task Assignment - Does "can be claimed by reviewers" mean the reviewer can self assign from a list of tasks? Does the "automatically signed based on configurable rules" mean the system may have logic to assign a subsequently submitted task to the person who is already handling a currently active task for that company/branch/individual? I assume it means other configurations are possible like assignment by alphabet or license type or task type. For Notifications, love the functionality to send blast notifications, branded by our agency to sets of licensees (steps 13 & 14). I may have missed it, but is there also functionality to send notifications to Organizational Users within my agency? The full requirements associated with task assignments and sending notifications still need to be developed. We'll be soliciting additional feedback on this topic once we get further along in the requirements process. Flagged for Future Response 61

63 #18 - Employment Relationship Lifecycle Personas: Journey Map Mary Individual Licensee (State) Company Organization User (State) (Company A) Barbara Company Organization Sarah Company Organization User (State) (Company C) Fernando Regulator Organization User (State A) Seymour Regulator Organization User Background: This journey discusses the proposed changes to employment, relationships, and sponsorships that will be implemented in 2.0. There will be a concept of "active employment", and a concept of "access". 'Active employment' with an entity means the entity has access to the licensee/registrant's record, and for state-licensed companies, the company is the assumed sponsor of the license. However, sponsorship will not be a separate activity outside of employment. 'Access' means licensees/registrants can grant access to an entity without actually being employed by that entity. If you have an employer and are creating a new account yourself, you can select your employer, which will create a task for the employer's org user to confirm employment. If the employer sets up the account, the employment is confirmed by default. When changing employers, the individual and new employer both must accept the new employment. This journey walks through the full employment relationship lifecycle, demonstrated by the experiences of a prospective individual licensee, Mary. Mary is new to the establishment of employment with Company A. After a few months at Company A, Mary accepts an offer from Company B, and grants Barbara access to her record prior to User (State) (Company B) (State B) leaving Company A. After a few months at Company B, Mary is terminated and remains unemployed for a period of time before being hired by Company C. Human activity System activity Version 2, Delivered 4/10/17 BULK Option to perform action in bulk Employed By Company A Employed by Company B Termination / Unemployment Employed by Company C Preceding Journey(s) #15 - Account Creation by CAA (for State-Licensed Companies) Individuals are prompted with a warning message to confirm the termination date prior to proceeding Subsequent Journey(s) N/A Mary, an Individual Licensee, has recently been hired to work for 's company, Company A. Mary is new to the industry, has no existing licenses, and does not have an NMLS account. creates an NMLS account for Mary, assigns her the roles and permissions of an individual licensee for the company, and enters Company A as her employer. As her employer, he automatically has access to her record and Company A will be the assumed sponsor of Mary's license. User Experiences: Barbara After logging in for the first time, Mary has a notification that Company A added her as an employee and her employment record has been updated accordingly. Mary selects the option to apply for a license to learn the requirements, completes her prelicensure requirements (e.g. testing, education, CBC, credit check, core data entry, document upload), completes her filing, and sends to for attestation and payment. The filing is reviewed and approved by Fernando. After a few months at Company A, Mary accepts an offer from Company B, and grants Barbara read-only, limited access to her record prior to leaving Company A so Barbara can see her record and start the onboarding process. Company A does not see that she granted access to Company B. Mary starts working at Company B. Mary clicks a link on her dashboard to process an employment change, which walks her step-by-step through the process. Mary enters a termination date and reason for Company A, which updates her employment record and removes 's access to her record. can still see Mary's information for the time she worked at Company A for historical and exam response purposes. Mary selects Company B as her new employer, which creates a task for Barbara to approve the employment. Barbara approves, which updates Mary's employment record and roles/ permissions to reflect the configuration for licensees for Company B. Alternatively, Barbara could send an employment request to Mary, which, once accepted, would update her employer and end employment with Company A. Mary is notified that Barbara approved, and is guided to attest to her employment change. Barbara receives a task on her dashboard to attest and pay for the employer change fee. Barbara can also select which licenses the company will sponsor. The employment change is reviewed and approved by Fernando. Mary is terminated by Company B. Barbara enters a termination date and reason, which updates Mary's employment record and removes Barbara's access to her record. Barbara can still see Mary's information for the time she worked at Company B for historical and exam response purposes. Mary is unemployed for several months before being hired by Company C, which does business in the state Mary was previously working in (A),as well as a new state (B). Mary's employment record displays a period of unemployment from the time she was terminated by Company B to the time she starts working for Company C, unless she held a job in a different industry, in which case she can update her record. Mary clicks the link on her dashboard to process an employment change, and adds Company C as her new employer. Sarah receives a task to approve the employment. Sarah approves, which grants her access to Mary's record, and updates her roles/ permissions to reflect the configuration for licensees for Company C. Mary's employment record is also updated. Alternatively, Sarah could have sent an employment request to Mary, which, once accepted, would have granted her access to Mary's record and updated her employer to Company C. Mary is notified that Sarah approved, and is guided to attest to her employment change for state A. She also selects the option to add a filing for another state, selects state B, and completes the filing, including one additional item not required by state A. Sarah receives a task on her dashboard to attest and pay for the employer change fee and new filing. The filings are reviewed and approved by Fernando and Seymour. Sarah I am able to configure and assign different roles and permissions to users within my company. Barbara I can grant access to entities of my choosing, even if they are not my employer. As an employer, I automatically have access to my licensees' accounts and am the assumed sponsor of their licenses. Sarah Mary The system guides me through the process of changing employers step-by-step. I can reset my password and recover my account without involving my company or calling customer support. Barbara Sarah Beginning/ending employment with an entity automatically updates my employment record and access to my account. I am able to assign tasks to my licensees when establishing an employment relationship. Mary Mary Mary Barbara Barbara Sarah I have access to my employees' records for the time they were employed by my company, even after they leave. I can configure the system to be the default payer for all of my licensees' activities. Barbara Fernando Seymour I am able to add a termination reason when terminating an employee. When I approve a license, I am also acknowledging the company's sponsorship of that license. 62

64 #18 - Employment Relationship Lifecycle NMLS 1.0 Pain Points: Users are unsure where to start in the licensing/ registration process. Varying state requirements (which are external to the NMLS system) create confusion during the filing submission process. Difficulty locating help resources on the Resource Center. Users have difficulty determining which license they should be applying for. Profile information is not validated against third party data sources. addresses are not validated and sometimes users will enter an incorrect address. The application workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process. Users are able to complete certain actions that their company may not want them to complete. There is an insufficient level of granularity when it comes to existing permissions. Users often don't know what exactly they are granting access to when providing access to another user. The system doesn't validate if a user already has an account, leading to the creation of duplicate accounts. When a company is granted access by an individual, they receive a notification that they were granted access, but it does not say who it was that granted access. The sponsorship approval process is currently an additional step after the license has been approved. Unable to communicate with other users in the system. NMLS 2.0 Capabilities: Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to request account access from an individual, or individual to request sponsorship. Ability to reset password without calling the Contact Service Center. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to configure if company or individual is primary payer (need to determine if this is a company or individual choice). Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to attach personal details to personal profile instead of to license, such that changing companies and getting a new license does not invalidate certain personal details (e.g. valid fingerprints carry over when changing companies and getting a new license/registration). Ability for individual to grant access to disclosure history (even at other companies) to their current employer. Ability to assist users with a step in the process based on the stage of the process and also on a page (i.e., context-aware help guides and videos to assist people with the process) help resources should be right on the page. Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to function as a real-time system where changes are reflected throughout the application immediately. Ability to send multiple notifications to different parties when actions are taken (e.g. individual is terminated by company, then individual, company, and regulator could all be notified). Notifications will be logged in audit trail. Ability to provide reminders for scheduled activities or other important dates. Ability to publicly (within NMLS, not Consumer Access) notate the reason why a change was made and capture free form notes to further describe the nature of the change. Ability to remove access to legal entities after leaving an entity either from termination or change in employment. Ability to view a MLOs record for periods employed (even if individual is no longer an employee). Ability for employers to manage an internal employee status (active / inactive, e.g. for military or other roles). Ability to combine logical workflow components to facilitate the user experience and reduce confusion/duplication (e.g. combine license and sponsorship approval). Ability to initiate tasks based on user actions, another user's actions (who create a task for you), or system generated activities. Ability to assign tasks to individuals/groups. Ability to see progress while completing the filing. (progress bar) Ability to dynamically require additional steps or uploaded document(s) based on pre-defined rules on fields such as license type and state. Ability to allow company or individual to indicate what a filing was for (e.g. on MU filings) so the filings can be identified later on (company level notes). Ability to upload data files from company HR systems to perform a validation against data in NMLS (reconciliation between HR systems and employees' NMLS records). Includes workflow and processing to compare uploaded data to NMLS data and provide a screen to decide which version to apply to NMLS (keep/overwrite). 63

65 NMLS 2.0 Journey Map Engagement Journey Map 18 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry What 'limited access' does Barbara have as Company B prior to employment? can Barbara view edu/test and what licenses they have? This would help w/ onboarding Mary to the company more efficiently. The historical view of previous employees is great, will help tremendously with examinations and monitoring. As well, I agree that what if Mary beats company A in putting in termination notice/date/reason - can Company A see that and have opportunity to add or adjust as necessary if incorrect? If Mary grants Barbara access to her record, Barbara would have read access and could see all her information. Flagged for Future Response Industry Industry When the relationship is created, the access is granted, and the sponsorship takes place all in one step, what happens if the company is starting an NMLS account for an individual before his/her start date? There will be a discrepancy between the account created date that reflects as the start date and the actual start date. (effective date and actual start date will be different). Pro: Company cannot see who else the individual has granted access to. Employed by Company A, Item 4: Will there still be NMLS Checklists and Professional Requirement (Education, Testing, CBC, etc.) available on the Resource Center or is that all handled within the system with the window pop ups as the individual walks through the process? We think that creating two different types of sponsorship (1) active employment and (2) access and addressing this relationship prior to application submissions is a good idea. We like the development of the progress bar concept. We envision 2.0 will have some form of checklist and the professional requirements fully integrated into the system. We also recognize there will likely be a need for some sort of external display of the requirements. What that is and how it will be accessed is to be determined. These details still need to be worked out as part of requirements.

66 NMLS 2.0 Journey Map Engagement Journey Map 18 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry 1. In regards to the Company () creating an employees NMLS account, it seems this could be an issue with some companies. There is a lot personal information that needs to be entered with each individual record. Since this is their account and their licenses, shouldn't be their responsibility to build and maintain their NMLS record? Or will the system have options? Both options will exist. Auto sponsorship could be a setting. No branch relationship is created. Flagged for Future Response 2. Sponsorship issue: Why would the system assume that we will sponsor all of her licenses or automatically sponsor her licenses since she is our employee? The issue we are thinking of is that we have employees that may apply for the wrong license or come to work with multiple licenses and if their branch is only licensed in one of those states we would want to be able to select the licenses we will sponsor. Maybe we are not understanding the automatic sponsorship feature in detail? :) 3. What permissions and roles is granting when he builds the account? Is this creating a branch relationship? Are we selecting states we will allow them to get licensed in?

67 NMLS 2.0 Journey Map Engagement Journey Map 18 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Step 2: I think there needs to be an option for the company user () to enter the information as well as the individual (Mary) to enter the information. Agreed - thanks. Flagged for Future Response Step 4: Again, I believe there should be an option for the company user () to select what licenses the individual (Mary) will be applying in addition to the individual (Mary) having that ability. This could be because the company may have certain states they need coverage in. Step 6: I like the ability to see employment history captured under Company A for exam purposes. This is a must, good capture! Again, could company user B process the necessary changes for the individual (Mary)? Steps 9/10: Same concept of having the company process in addition or replacement of the individual. This one has a lot of moving pieces and a little difficult to follow. However, I think we just need the ability to process everything from a company user standpoint as well as the individual. I understand the individual accounts are owned by the individual and need to be attested and kept up to date, but think some companies process a lot of changes and updates for MLO s where all they need to do is review and attest. Industry Regulator Step 5: What is the vision around the limited access that Company B would be able to see upon going into Mary s account while she is still with Company A? Things that would be helpful in the preonboarding process would be able to see things such as disclosure questions, education history as well as the licensing history. Step 6: Great addition of having access to the MLO history for historical and exam purposes! So happy to read this! Will be super helpful! Map # 18 - What about states that require MLOs to work at a licensed location and need to determine whether distance between MLOs home and work location is reasonable? Thanks! We think so too and are excited to demonstrate this to folks soon. The ability for both regulators and licensees to be able to determine distances is something we've had multiple request for and is on the list for requirements.

68 NMLS 2.0 Journey Map Engagement Journey Map 18 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry In Step 6, it indicates that Mary will be prompted to enter a date and reason for termination. If Mary beats Company A in inserting this data, will there still be opportunity for Company A to report the termination through the NMLS system that is visible to regulators to ensure accurate termination date, as well as reason, is entered? Meaning, there could be additional details that we would want the regulator to know. Also, will the date of termination entered automatically show on Consumer Access and update the employment history to show they are no longer at Company A? On the note of termination, could we also consider building in the NMLS 2.0 system (at some phase) the termination process some states hold when letting a MLO go for certain reasons? It be great to have one stop shop for the termination process and keep everything in the one system of record. Some states require additional notices/forms be sent outside of NMLS. Step 8: When Company B terminates Mary, is it possible to give the company the ability to select states in bulk when choosing the licenses on each individual when removing state sponsorship? This is very detailed and we will revisit during user stories. Flagged for Future Response X

69 NMLS 2.0 Journey Map Engagement Journey Map 18 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry 1. Once Mary completes all of her pre-license requirements and is ready to apply, why does it go back to to attest and pay? In the case where a company does not pay for the M LO licenses, will we have the ability to attest and send back to Mary to pay? Yes - MLOs will be able to attest and pay. Great! Roles and permissions are defined in a different JM. Great idea on employment history - maybe we should think about not having it self reported and emphasizing company verified employment? Flagged for Future Response 2. Being able to view all employees that have worked for us and their history of audit purposes is a GREAT enhancement!! 3. It looks like when Company B accepts employment for Mary she can select the state licenses she will sponsor. It is not clear what roles and permissions can/will be granted to Mary by employer. 4. When Mary is terminated by Company B. does the employment record get updated even if Mary does not hold any licenses. Currently we cannot change or update employment histories of anyone who does not hold a license.

70 #19 - Effective Dated Changes (Previously Amendments / ACN's) Personas: Journey Map Company Organization User (State) Background: A state-licensed company has decided that it will be changing its legal name, with the change scheduled to go into effect in 90 days. is responsible for making the required changes to the company's record in NMLS and submitting the required filings. Failure to comply with the state's requirements of providing 60 days notice for this type of change could result in fines and penalties. logs into NMLS, clicks on the quick link on his dashboard for making changes to company records, and can easily find the state's requirements, which Sam previously configured in the regulator portal. The requirements tell which information requires advance notice for changes, and which information does not. is then guided step-by-step through the process of updating the company record, which automatically triggers and populates the required state filing. Sam has the option in his regulator dashboard to configure whether he gets a task or a notification for this type of change. In 2.0, a simplified process for updating records will require all changes to have an effective date, with regulators able to configure which changes require advance notice and / or review. Sam Regulator Account Administrator (State) Human activity System activity Version 2, Delivered 4/10/17 BULK Option to perform action in bulk Preparation Preceding Journey(s) N/A Company Updates Review / Approval Subsequent Journey(s) N/A A state-licensed company has decided that it will be changing its legal name, with the change scheduled to go into effect in 90 days., responsible for making the required changes to the company's record in NMLS and submitting the required filings, logs into NMLS to learn the state's requirements for changes. User Experiences: clicks on the quick link on his dashboard for making changes to company records, and can easily find the state's requirements, which Sam previously configured in the regulator portal. The requirements tell which information requires advance notice for changes, and which information does not. learns that failure to comply with the state's requirements of providing 60 days notice for this type of change could result in fines and penalties. begins making the appropriate updates for the change in legal name, and is guided step-bystep through the process of updating the company record. changes the company's legal name to the new name, and adds an effective date of 90 days in the future. He makes these changes to the company record, which automatically creates filings that are prepopulated with the required information. The state only requires 60 days notice for the changes, so 's changes comply with the requirements. Alternate Step: If the effective date had been less than 60 days in the future, is still allowed to proceed, but is notified that he may be out of compliance with state requirements. may also backdate a change (scope of what can be backdated is still pending), but this may trigger a flag for regulator review. uploads the required legal documents. He also provides a detailed narrative of the changes in the notes section to provide guidance to the regulator and expedite processing. attests to all changes, pays the change fee, and submits the filing. The system performs a completeness check prior to allowing him to submit. Sam, who can configure which changes trigger notifications only, and which changes trigger a task for review, receives a task on his dashboard to review the change in legal name. Sam accesses the filing and notes, a detailed change log, and documents from his review filing dashboard and begins his review. He places action items if there are any deficiencies or he needs additional information. Sam can also include internal notes, set due dates for the action items, and his contact information is included with the action item. Sam reviews all of the information included with the changes, and provides acknowledgment. receives a notification that his changes have been acknowledged. I can easily access all of the state's requirements for making updates to my company and individuals' records from within NMLS. I am presented with a list of the information that requires advance notice to update, and which information does not. Sam I can configure which information requires advance notice to update and which information does not from within my regulator portal. Sam I can configure which changes trigger notifications only, and which changes trigger a task for review. The system walks me through a step-by-step guided process to make updates to my records. After 90 days, is notified that the changes he made 90 days ago went into effect; however, no action is required on his part. The system automatically creates filings and prepopulates them with the updated data that I entered in my company and individual records. I can provide a detailed narrative of the changes I am making to provide guidance to the regulator and expedite the review process. I am able to complete all steps of the update process within NMLS, including communicating with other users and uploading/ submitting all documents. Sam I can configure which notifications my agency users receive on their dashboards. Sam The system maintains a detailed audit trail of all changes that I can access to help in my review. 68

71 #19 - Effective Dated Changes (Previously Amendments / ACN's) NMLS 1.0 Pain Points: The process for completing and reviewing amendments and ACN's is overly complex and causes confusion. There are a variety of different ACN statuses used in the system. Should have option to NOT provide advanced notice. This would drastically reduce the amount of ACN work items that are not ACNs. The sheer volume of amendments clogs up and muddles the work list. There is no difference in treatment between trivial and non-trivial changes. Not all agencies participate in the ACN functionality. There are multiple ways to communicate issues with change ACN Status update vs. license items. ACNs process on the designated effective date regardless of the ACN status. Regulators don't have the ability to update the status of a processed ACN. Users are confused with the buttons to submit amendments, 1,000 amendments can be displayed with no change in the record, but still need to be verified which takes up time. States have varying requirements for amendments and ACN's which causes confusion. States require documentation to be submitted outside of NMLS. Users don't know when advanced notice is required and when it is not. Changes can only be triggered from a filing, but the change is not reflected in other areas of the system. NMLS 2.0 Capabilities: Ability to make multiple payments in one invoice similar to a shopping cart concept Ability to upload documents at various points in workflows (including when responding to license items). Ability to easily toggle between one entity and another for which the user has an admin or organization role. Ability to track all actions, activities, and changes with an audit trail (e.g., who, what, when, why). Ability to separate ACNs from renewals. Ability to attach personal details to personal profile instead of to license, such that changing companies and getting a new license does not invalidate certain personal details. Ability to view/generate a full or object-level audit trail (e.g. list of changes made to a company license record). Ability to attach regulator/reviewer contact information to license items/communications. Ability to publicly (within NMLS, not consumer access) notate the reason why a change was made and capture free form notes to further describe the nature of the change. Supports regulator review and ability for companies to identify the differences between and reasons for amendments/ filings. Ability to combine logical workflow components to facilitate the user experience and reduce confusion/duplication. Ability to set regulator fees and other configurable license requirement and workflow settings. Ability to bulk upload data (file upload) or bulk complete actions (multi-record select) in order to complete actions on multiple records at once (e.g., application withdrawal). Ability to dynamically require additional steps or uploaded document(s) based on pre-defined rules on fields such as license type and state. Ability to provide e-signature capability for any forms / documents requiring a wet signature. Ability to communicate with other users within the system. Ability for system to identify records that pass all regulator-defined checks with ability to single-click approve that population. Also, ability to configure automatic approval for that population. Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to trigger reviews based on defined and configurable business rules (e.g., If a new MLO, review record before submitting or if existing MLO, and low risk, possibly automate). Ability to automatically update object record data when actions are taken on that object (e.g. update employment record when hired / terminated / transferred). Ability to auto-assign certain tasks by state, work item type. Ability to configure auto-approval thresholds (e.g., credit checks, CBC, etc.). Ability to upload data files from company HR systems to perform a validation against data in NMLS (reconciliation between HR systems and employees' NMLS records). Includes workflow and processing to compare uploaded data to NMLS data and provide a screen to decide which version to apply to NMLS (keep/overwrite). Ability to assist users with a step in the process based on the stage of the process and also on a page (i.e., context-aware help guides and videos to assist people with the process) help resources should be right on the page. Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to highlight form changes to expedite review. Ability to function as a real-time system where changes are reflected throughout the application immediately. Ability to initiate tasks based on user actions, another user's actions (who create a task for you), or system generated activities. Ability to send multiple notifications to different parties when actions are taken (e.g. company record is updated). Notifications will be logged in audit trail. Ability for users to assign roles and permissions (delegated authority within parameters/capabilities granted in the admin dashboard by SRR). Ability to tag documents with metadata in the document upload section based on workflow and context. Ability to not show corrections (mistakes) to the public, but allow State Regulators, LO, and those who have been granted access to the record to see the history of changes (i.e., the public should only see the most recent, up-to-date record). Ability to store company documents in a central location. Ability to access historical data. Ability to have a single login/profile, with access and association to multiple entities. And the ability to identify and change what entity you are working on currently and all entities that you have access to in the system. 69

72 NMLS 2.0 Journey Map Engagement Journey Map 19 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Map #19 - Will a regulator have to receive notice of all Effective Dated Changes, or will we be able to choose categories of changes for notification? SRR is still working out the requirements for exactly how effective change notices will work. Do you have a preference? Flagged for Future Response X Industry Industry Map #19 - in action 7, uploads the required legal documents. For a legal name change in particular, those documents are not available until the legal name change occurs, so those documents will not be available for at least 90 days. Will NMLS 2.0 allow the ACN to go through without these documents? Certainly licensees will be able to post notes advising that such documents will be uploaded as soon as they are available, but licensees need to be assured that the system will allow the function even if not all documents are uploaded at the time of submission. #19 Effective Dated Changes (Previously Amendments/ACNs) What about State s that don t utilize the NMLS currently to conform to this automatic ACN on the effective date? Ex: New York, if had NY license, they would require the company to receive written notification of approval and the new license showing the approved change before transacting business under the new name. This currently causes issues as the system might say approved, but in reality we cannot conduct business in one state out of 50 when that 90 days comes up Does every state have to acknowledge the ACN for it to be approved or will some States simply not utilize this functionality (as presently found)? Can more than just, w/in the Company, receive the notifications? Ex: can assign his Company AA to receive the notifications as well? Having the regulator contact info is great on the ACN once they acknowledge so can communicate outside NMLS if necessary w/ the appropriate person. Good feedback. We're still working on the specific details about how change notices will process in 2.0 and take this into consideration. Full details about how change notices will work still need to be worked out, but we're very focused on addressing the type of items you bring-up. As details are fleshed out we'll be sharing them with industry as we recognize this is a major point within the current system. 70

73 NMLS 2.0 Journey Map Engagement Journey Map 19 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry A list of state-specific requirements should be readily available concerning the grounds for changes/acns. For example, NY calls the agent to get any ACN amendments confirmed and finalized, while other states will use correspondence. Some states will give the agent 5 days while others will give the agent 60. Some states will even want updated bonds or leases. There are also some states that do not care about any ACN changes or amendments. Full details about how change notices will work still need to be worked out, but we're very focused on addressing the type of items you bring-up. As details are fleshed out we'll be sharing them with industry as we recognize this is a major point within the current system. Flagged for Future Response 71

74 #20 State License Surrender/Withdrawal Personas: Journey Map Sam Regulator Account Administrator (State) Background: The purpose of this journey is to highlight the key user experiences associated with surrendering an active state license and withdrawing a pending state license under regulator review. Surrendering a license takes place when an individual or company wants to give up the right to conduct business in a given state. This decision requires the individual or company to turn in the active license to the state agency and comply with any additional state-specific surrender requirements. Withdrawing a license occurs when an entity no longer wishes to obtain a license and removes a pending license from state regulator consideration. The scenario below captures the key user experiences that Jim, an NMLS User with an active company and branch license in the system, encounters when he learns that his company is going out of business and withdraws a pending license and surrenders the existing licenses. Note: If an individual or company does not renew their license, they can either surrender, or allow the license to become inactive. If the individual keeps their professional standards current while the license is inactive, they can easily re-activate it by submitting a pre-populated filing. Note: the license surrender process is different for company, branch and individuals based on state requirements. Jim Company Account Administrator (State) Human activity System activity Version 2, Delivered 4/10/17 BULK Option to perform action in bulk Preparation Withdraw Surrender Confirmation Preceding Journey(s) Subsequent Journey(s) License Surrender: #7 - State Regulator Review of Company/Branch Filing N/A #9 - State Regulator Review of Company/Branch Renewal (Exception Handling) License Withdrawal: #2 - State License Filing Submission for a Company/Branch Jim's company is going out of business, and Jim needs to withdraw a pending license and surrender the company's existing company and branch licenses. User Experiences: In the licenses section of his dashboard, Jim clicks the withdraw button directly next to the pending license that is currently under regulator review. Upon confirming his selection to withdraw his filing, the system automatically cancels the filing. Sam, a Regulator Account Administrator (State), has the option to be notified of a withdrawn license, but no action is required on his part. Returning to the licenses section of his dashboard, Jim selects his company and branch licenses and clicks the surrender button. The system provides Jim with a guided process to walk him through the surrender process. This includes completing statespecific surrender requirements for his particular license type (e.g., uploading the required documentation by the state agency and confirming no existing loans in pipeline). Sam Jim uploads the necessary documentation to adhere to the surrender state-specific requirements, adds any additional notes to further explain the situation, attests, and submits the surrender request in the system. Note: If a company license is surrendered, the underlying branch licenses must also be surrendered, and any individual licenses the company was sponsoring would move into an inactive status. Sam Sam, a state Regulator Account Administrator, can choose whether he wants to receive a task to review the surrender, or simply be notified. Sam can also run a report from within the system to view all license surrenders and withdrawals to analyze trends, etc., and if necessary, make any notes in the system. Jim Jim I am able to complete all steps of the surrender/withdrawal process within NMLS, including communicating with other users and uploading/submitting all documents. The easy-to-follow guided process walks me through all of the steps required to withdraw a filing or surrender my license. Sam If I have a question while I am withdrawing a filing or surrendering a license, I can access specific help resources right on the screen I am working on. I can communicate with other users in the system to get the information I need. The user interface for creating new or editing pending filings is very intuitive and well organized. Jim Jim Jim I am able to view reporting on license surrenders and filing withdraws. The buttons to surrender and/ or withdraw a filing are clearly displayed for me to take the appropriate actions. My streamlined and customized dashboard helps me stay organized by displaying my work items in a prioritized manner. 72

75 #20 State License Surrender/Withdrawal NMLS 1.0 Pain Points: Varying state checklist requirements (which are external to the NMLS system) create confusion during the filing process. Regulators have to deal with incorrect interpretation of checklist items. The review workflow is complex, not intuitive, and does not provide transparency into what items I need to review. Difficulty locating help resources on the Resource Center. The action buttons to edit a filing and withdraw and/or surrender are not easy to find on the screen. Unable to communicate with other users in the system. There is no ability to track changes to records or provide an audit trail of actions. The system does not provide licensing history. The worklist is very confusing, does not allow a user to prioritize items, and contains items that don't even require action. Users are unable to customize the view of a worklist. The worklist doesn't provide an accurate picture of a user's true workload. No ability to mark items as resolved or clear them from the worklist. NMLS 2.0 Capabilities: Ability to include state agency requirements and allow state agencies to edit these requirements. Ability to dynamically require additional steps or uploaded document(s) based on pre-defined rules on fields such as license type and state. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to customize the view of the dashboard by task, industry, company, or other attribute. Ability to prioritize and assign workload. Ability to limit access to sensitive documents / data in the system by group / user. Ability to see other state regulator notes on credit report reviews (need to think through privacy concerns). Ability to bulk upload data or bulk complete actions (multi-record select) in order to complete actions on multiple records at once (e.g., approve multiple licensees). Ability to send multiple notifications to different parties when actions are taken (e.g. license is approved) Ability to configure automatic approval (e.g., the ability to automatically approve a sponsorship with an approved license and employment relationship). Ability to provide insight into state regulator review progress. Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to download documents for review. Ability to communicate with other users within the system. Ability to ensure positive confirmation of what is being worked by the regulator (and who is working it, particularly where problems are identified). 73

76 NMLS 2.0 Journey Map Engagement Journey Map 20 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Only comment or concern on this map is it sounds This map is Expo licensed during concern user story like 2.0 will make it easier to surrender and withdraw session. licenses, so when submitting a filing how many warnings does the system give us as to "Are you sure you want to Surrender/Withdraw" this license? Flagged for Future Response Industry Industry The Licensing team wants to ensure the Background section of this is interpreted correctly; will the licenses not 'surrendered' during renewals that become 'inactive' be terminated after End of Year? or stay 'inactive' until surrendered? Currently if not surrendered most states put into a terminated stated after End of Year. Also, even though this might be jumping forward, the licensing team wants to know if the Do Not Renew option will still be there for licenses at end of year? for surrendering license, Step 3, is this only for company or individual licenses as well? It would be helpful to have the ability to notify States of their requirements for surrender on an individual level w/in the system as well as the company - would allow for a streamlined process on both ends. -If an individual surrenders or opts to withdraw their license; do only they confirm or can the company have to opportunity to confirm... or at least get notification of such action taken by an individual? This way if the individual accidentally w/d or surrenders a license we can help guide them to get it back and/or turn off their ability to do business ASAP so we are incompliance. Looks good and fairly simple, however, just would like to see a few controls or checks confirming the company really wants to surrender prior to submission. We anticipate that users will be alerted and directed to resolving issues well in advance of raw surrender period. We anticipate that users will be alerted and directed to resolving issues well in advance of raw surrender period. 74

77 NMLS 2.0 Journey Map Engagement Journey Map 20 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Flagged for Future Response Industry Random question: if it is determined in the system that a company pays for an MLO's licenses and sponsors them, during that time, is there a way to shut down the ability for an MLO to surrender those licenses and put that in the company's discretion only? This question is somewhat feeding off of Cilla's last comment above if the MLO takes action and then it being sent to the company for review to determine if this is the desired action or not before they are not able to originate. Regardless of who pays and if the company is "sponsoring" the license and thereby responsible for actions taken under the licensee, it is important for the sponsoring company to have knowledge of all actions, including surrender requests, submitted by the individual. Consistent with the principles that an individual is the one assigned to the license, a company, regardless of their role, cannot impede the actions of the individual when referencing their own license. Insight into and possible acknowledgement of such action is feasible and makes sense. As we build a system for companies to rely on NMLS for their compliance and for continued individual responsibility, these concepts will need to be further explored and defined to achieve the balance of understanding of what truly is a compliance concern vs. a production or administrative process improvement. Industry Regulator Preceding Journey, Item 3: Will there still be NMLS Checklists available on the Resource Center or is that all handled within the system with the window pop ups as the individual walks through the surrender process? Ability to provide e-signature capability for any forms/documents requiring a signature will all state-specific forms that are required to be sent via hard copy to the regulator (i.e. Minnesota Disclosure of Owners and Officers form) now be required to be e-signed in NMLS rather then sending it to the regulator via hard copy Ability to download documents for review will a licensee have access to download the items required to a particular task (license surrender, de novo license application, amendment filing) prior to beginning such task in the NMLS. When a company surrenders all of its licenses, if the Noted. license is subject to filing a MCR, MSB Call Report, or other similar report in NMLS, the company should be required to complete the filing for the last quarter in which the company 's licenses were active. We anticipate that users will be alerted and directed to resolving issues well in advance of raw surrender period. 75

78 #21 - Transitioning a License Personas: Journey Map Jim Company Account Administrator (State) Ryan Company Control Person (Direct Owner) Sally Company Control Person (Branch Manager) Mary Individual Licensee (State) Sam Regulator Account Administrator (State) Background: Human activity System activity API API Gateway Version 2, Delivered 4/10/17 This journey details the experiences involved in transitioning company, branch, and individual licenses onto NMLS. A state agency has decided to transition a license type onto NMLS, and issued a deadline for all license holders to complete the transition by the end of the year. The agency is also requiring all control persons and individual licensees to complete new CBC's and credit checks through the system. Jim is responsible for managing the transition of the company, branch, and individual licenses onto the system. His company has never used NMLS before, so the journey covers the end-to-end process of creating accounts, setting up company, branch, and individual records, completing professional standards requirements, selecting the option to transition a license, and completing the filings. Sam's agency utilizes the auto-approval functionality for the transition filings as the licenses are already issued, and compares the data from the filings to data stored in their internal system using the API gateway to ensure consistency. BULK Option to perform action in bulk New License Type Configuration Account Creation Pre-Licensure Requirements Company/Branch Setup License Type Selection Transition Filings Regulator Review Preceding Journey(s) Subsequent Journey(s) N/A N/A A state agency has decided to transition a license type onto NMLS, and issued a deadline for all license holders to complete the transition by the end of the year. The agency is also requiring all control persons and individual licensees to complete new CBC's and credit checks through the system. User Experiences: Jim Sam, a Regulator Account Administrator, notifies Jim's company outside of NMLS that the license type is being transitioned. He also uploads a list of all licenses that Jim's company holds, including branch and individual licenses, into NMLS. The list includes the existing license #'s, company EIN, individual SSN's, and other data the agency wishes to include. The data will be used to perform completion and validation checks against the data that Jim enters for each license. Note: the data provided by each state will vary. Jim creates an Account Administrator account for himself, creates the company record, and creates accounts for company users using the bulk upload template, including Ryan, Sally, and Mary. The bulk upload template also populates the users' core data. During account creation, Jim indicates that he is transitioning an existing license, which places him into a guided workflow that walks him through each step. See #15 - Account Creation (for state and federal entities) for more details on this process. BULK Jim completes account setup for Ryan and Sally, uploads documents required for the license type, schedules fingerprinting, and authorizes credit checks. Mary completes all of these steps on her own. See #1 - Pre-Licensure Requirements (Individual State Licensee) and #37 - Pre-Licensure Requirements (Control Person) for more details on this process. Jim completes the company and branch record set up. Jim adds Ryan and Sally as control persons, and the system creates and sends them control person filings for attestation. See #38 - Company / Branch Setup for more details on this process. Jim is prompted to select the specific license type he would like to transition as well as the state. Jim selects the appropriate licenses and is provided with the transition requirements. Jim gathers the required information / documents, and is now ready to begin his company and branch filings. Jim initiates the company and branch filings, enters the existing license numbers, and is guided through the filing process step-by-step. See #2 - State License Filing Submission for a Company/Branch for more details on this process. When transitioning licenses, the guided process walks me through the filings step-by-step. I am able to quickly and easily navigate throughout the different sections of the filing and the onscreen status bar keeps track of my progress. The system performs a completeness check and notifies me of any missing information before allowing me to submit. Jim Jim Ryan I am able to resume a filing I started previously from the license dashboard. Sally BULK I receive an notification that a company has created an individual filing on my behalf that requires my attestation. The system pre-populates filings by pulling information stored in the company, branch, and individual records. I can attest to my filing on my mobile device, and can get to the attestation page from a link found in the I receive. I am able to pay for multiple licenses at one time. Jim Jim Jim Jim Ryan Sally Jim Mary After submitting the company and branch filings, Jim is prompted to submit filings for individual licensees, if applicable. Jim initiates the filings with a bulk upload template that includes the existing license numbers, and is guided through the filing process step-by-step. See #3 - State License Filing Submission for an Individual Licensee for more details on this process. BULK If I have a question while I am completing the filing, I can access specific help resources right on the screen I am working on. I can transition individual licenses in bulk using a bulk upload template that contains the existing license numbers. The filings run through regulator-defined rules/ thresholds and any items that require additional review are flagged. If no items are flagged, the system automatically approves the filing. Sam reviews any flagged items, and places action items if there are any deficiencies or he needs any additional information. See #7 - State Regulator Review of Company/ Branch Filing and #8 - State Regulator Review of Individual Licensee Filing for more details on this process. Jim Jim Sam wants to compare the data from the filings to data stored in his agency's internal system to ensure consistency, and uses the API gateway to perform the comparison. He places action items if there are any discrepancies. API I am able to seamlessly transition my existing license into NMLS. I am able to complete all steps of the application filing process within NMLS, including communicating with other users and uploading/ submitting all documents. 76

79 #21 - Transitioning a License NMLS 1.0 Pain Points: Company users currently have to pay for individual licenses one at a time. Users do not receive confirmation that their filing has been successfully submitted. License status names are not intuitive (e.g., Pending- Incomplete) and may not be used the same way across agencies. Applicants are unsure of the status of their application after submitting. When addressing disclosure questions, if a user answers "Yes", the user does not know what documentation to upload. Unable to communicate with other users in the system. Control persons unable to update their records without involving other company users. Need to log in and out constantly to attest to filings and changes. Lack of settings to enforce specific document uploads based on license type. Agencies have difficulty managing the volume of uploads and identifying changes to documents. States often require documentation that is not on the checklists. Unable to upload certain documentation upfront to provide information the state wants (e.g., work authorization). The upload functionality is limited: unable to provide more than one document at once, size limit constraints, document choices are limited, and wet signature required for some states. Lack of data uniformity across states (e.g., certain states care about "St." vs. "Street.") Criminal Background Check process does not include fingerprint scheduling. The application workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process. Users do not have the ability to place notes on a filing. (e.g., a note indicating what a filing was for so the fillings can be identified later on.) Company users are unsure of where to start in the licensing process. Varying state checklist requirements (which are external to the NMLS system) create confusion during the filing process. Difficulty locating help resources on the Resource Center. The transition workflow is clunky and causes confusion. NMLS 2.0 Capabilities: Ability to make multiple payments in one invoice similar to a shopping cart concept. Users are able to withdraw an application at any time in the process. Ability to have insight into state regulator review progress. Ability to upload documents for review by the selected state licensing authorities. Ability to upload multiple files at one time. Ability to tag documents with metadata in the document upload section based on workflow and context. Ability to send multiple notifications to different parties when actions are taken. Ability for companies to control what steps individuals have access to. Ability to assign tasks to individuals/groups. Mobile capability for core licensing workflow functionality (smartphone, tablet). Ability to notify users via . Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to leave and come back to a filing and resume in the same location (i.e., save and continue). Ability to include State Agency checklists / requirements and allow State Agencies to edit these requirements. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to bulk upload data (file upload) or bulk complete actions (multi-record select) in order to complete actions on multiple records at once. Ability for companies to control what steps individuals have access to. Ability to assign tasks to individuals/groups. Ability to re-use background and credit checks that are stored in a user's record. Ability to see progress while completing the filing (e.g., visually represent with a status bar where the user is in the overall filing workflow). Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to request account access from an individual. Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to communicate with other users within the system. 77

80 NMLS 2.0 Journey Map Engagement Journey Map 21 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry #21 Transitioning a License Step 4, can Jim complete the account setup for Mary and have her validate? I believe #1 Journey Map I asked the same thing so these correlate Step 7, can Jim access the requirements for transition prior to this step? So he can gather this information ahead of time, if necessary Step 11, the API gateway will be great for comparison to ensure company internal systems are accurate to the NMLS. Yes, it is envisioned the process would work very similar to maps 1 and 3 where the company account administrator set-up the account for the licensee and the licensee then goes in, validates the information and then will attest. Flagged for Future Response 78

81 #23 - Invoice Management Personas: Journey Map Projected Renewal Costs Jim Company Account Administrator (State) Company Organization User (State) Version 2, Delivered 4/12/17 Background: Jim, a Company Account Administrator (State), is preparing his organization for the upcoming renewal season. As the company will be renewing all company, branch, and individual licenses, there will be a number of invoices to pay. The various types of activities that require invoices include renewals, amendments, assessments (based on loan volume, # of MLO s, # of branches, etc.), exams, credit checks, CBC's, and surrenders. The ability to easily manage all of the various invoices is crucial to successfully make it through renewal season. This journey captures key capabilities needed for invoice management, such as projecting renewal costs, adding/updating payment information, delegating invoice payments, ability to make bulk payments or create bulk invoices, adding notes to invoices, making payments for all activities within NMLS, accessing easy-to-use reports, and searching/filtering for invoices. Updating Payment Information Preceding Journey(s) N/A Sam Regulator Account Administrator (State) Invoice Payment Companies have the ability to delegate an invoice to an individual, and vice versa. Invoice Creation Human activity Creation of some invoices could be automated, such as year-end assessment fees based on data in the system (e.g. % of loan volume, # of MLO s/branches, etc.) System activity BULK Option to perform action in bulk Accounting Reports Subsequent Journey(s) N/A As renewal season approaches, Jim wants to get a better sense of what his company's total costs will be for renewing all company, branch, and individual licenses. Utilizing the projected cost functionality within NMLS, creates an estimated total cost report. Note: Projected cost functionality can be used for other activities as well. Jim's company has recently opened a new bank account, and needs to add the account within NMLS to pay for renewal fees. Note: Users will have the ability to update existing account information. User Experiences: From his dashboard, Jim clicks on the link for payment information and adds the bank account. The account is validated by the system. Jim has delegated responsibility for paying all invoices to, a Company Organization User. plans to consolidate all renewals submitted that day into a single invoice for payment, similar to a shopping cart. Note: Jim also has the option to add an effective date to invoices to be paid in the future. selects all of the renewals that have been attested to that day, adds them to his shopping cart, and pays for them in one bulk payment. This will be considered a single invoice with many line items. The renewals are submitted and paid for at the same time. Note: Timing on renewal payments can differ between state and federal entities. As prepares to make the payment, he is able to choose from all available payment methods (bank accounts, credit cards) that have previously been added, and can see the account details. He can also add notes to make it easier to find the invoice later. immediately gets a confirmation number, and the payment is reflected realtime in the system. can view the invoices and within the invoices see all the individual detail as well. Sam, a Regulator Account Administrator (State), is responsible for issuing invoices to companies licensed in his state. He has a number of invoices to issue for miscellaneous reasons. Sam clicks on the invoice link from his dashboard, and is presented with the option to create a single invoice, or create invoices in bulk. Sam wants to utilize the bulk creation method, and downloads the bulk invoice template. Sam populates the template with all of the invoices he wishes to create. He is also able to include multiple items on a single invoice for a specific company/individual, such as a one-time penalty and amendment fee on the same invoice, and attach any relevant artifacts. Sam uploads the template, which creates the invoices and payment tasks for all of the recipients indicating they have a new invoice to pay. Sam can also include notes with each of the invoices explaining the charges in more detail. After receiving notifications on their dashboards, the various company and individual users pay their invoices. All invoices are now paid for within NMLS, even for any activities that occur outside of the system that relate to licensing, in order to provide a full audit trail within the system. Note: If a payment is late a certain number of days, the system will lock the account and send notifications requiring invoice payment. At the end of the year, Jim's company and Sam's agency prepare to close their books. Jim and Sam are responsible for accessing all payment activity for the year from the system and providing it to their respective accounting departments. Jim and Sam access easy-touse accounting reports (e.g., disbursement reports) from the system, which contain detailed information on all of the invoices paid or received over the course of the year. I am able to project what my company's total costs will be for renewing all company, branch, and individual licenses. I can easily add a new bank account or credit card for making payments in the system. BULK I can delegate responsibility for making payments to one of my company users. I can pay for multiple items in one invoice similar to a shopping cart concept. I can select the payment method I want to use for each invoice, and can see the details of the bank account or credit card. I can make single-click payments instead of navigating through multiple payment screens. I immediately get a confirmation number with each payment. Jim Jim Jim BULK If their accounting departments have questions on specific invoices, Jim and Sam can easily search or filter for an invoice to obtain additional information or view any notes. Payments are reflected real-time in the system. I can create invoices in bulk by utilizing the bulk invoice template. I can include multiple items in one invoice. I am able to attach notes to an invoice. I can pay for all licensing invoices within the system, instead of having to remit payments directly to state agencies. Sam Sam Sam Jim Sam I can include custom fields such as cost center in the system to make it easier to perform internal reconciliations. Jim Sam I can access easy-to-use accounting reports from the system with details of all payment activity. Jim Sam I can easily search and filter for specific invoices. Jim I can establish a default payment method and later choose a different option. 79

82 #23 - Invoice Management NMLS 1.0 Pain Points: Multiple fees (e.g., change of control, late penalties, exams, failure to notify) are paid outside the system. State Agency fees are currently tied to filings, but these fees should be tied to the entity. No ability for sponsors to see/pay for an individual s invoices. Inability to provide company specific accounting codes to an invoice to simplify the internal reconciliation process. System does not provide an internal note field for invoices. Inability to capture an employee's supervisor in NMLS so that he / she can be included in communications with the MLO. Difficult to search for invoices and what has been paid for. ACH payments do not have upfront account validation or real-time notifications from payment processor. Need more detail on the period of the payment the item relates to. Unable to download all the information on an invoice. Unable to see saved account information when making a payment. Inability to batch invoice. Inability to include custom fields such as a credit card account. Disbursement reports cannot be customized by user which creates challenges when states may recognize revenue differently (e.g., license types or fee types). NMLS 2.0 Capabilities: Ability for companies to request removal of invoices for duplicate activities; and for SRR to delete invoices. Ability to configure invoice and payment of other invoice types in the system that can be issued by state agencies. Ability to assign responsibility for an invoice to company (by individual) or to individual (by company). Ability to make multiple payments in one invoice similar to a shopping cart concept. Ability to generate an invoice with multiple items. employees invoices. Ability for SRR to obtain data/extracts/reports that represent unpaid invoices (accounts receivable), aging of those invoices, and show the data by entity. Ability to search and download payment and invoice details. Ability to configure if company or individual is primary payer (need to determine if this is a company or individual choice). Ability to create unique confirmation codes for payments. Ability to validate ACH accounts upfront (is it a valid account). Ability for the system to have a data interface with the payment processor (vendor). Ability to accept multiple forms of payments including: credit cards, and ACH. Ability to send notification of ACH clearance. Ability to receive more near real-time notifications if there are insufficient funds. Ability for the system to have a data interface with a general ledger to post journal entries. Ability to take actions on invoices and have those impacts reflected in the general ledger and system (e.g. write-offs, refunds, cancelled invoices, chargebacks etc.) Ability for SRR to obtain data from the system to perform summary reporting and reconciliations to bank accounts. 80

83 NMLS 2.0 Journey Map Engagement Journey Map 23 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Industry When we complete a filing that will have fees associated with it, such as applying for a license, ACN, Renewal, sponsorship, etc. will we pay at time of filing or will each state invoice us for multiple filings in one invoice? It is currently envisioned that the company will pay at the time of filing with options to pay for a single entity or multiple entities on one invoice. It would make a great difference if there was an Good feedback and we'll see what we can do. option on the NMLS where Licensing could see all transactions done under their agent s accounts. This would make for easier receipt saving and tracking of credit card transactions done under the company s card. For example, we have the save the receipt under the agent s account. Flagged for Future Response Federal Registrants #23 Invoice Management Step 5 Need to know the difference between State and Federal Process During January meetings in Charlotte, we discussed ability to fund a prepaid account within NMLS and funds automatically withdraw as we confirm employments or renewals are processed Has that option been removed? We likely will not do a pre-paid account for 2.0 launch. However, we still believe there is merit in the idea and may explore as part of a future release. 81

84 #24 - Mergers and Acquisitions (M&A) (Federal) Personas: Journey Map Acquisition Overview Henry Institution Account Administrator (Federal) (Institution A) Cornelius Institution Account Administrator (Institution B) Acquisition This journey captures the experiences of two federally-registered institutions combining as a result of a publicly announced merger, acquisition, or corporate reorganization. Under the SAFE Act, institutions have 60 days from the transaction effective date to complete the transfer of individual registrations from the acquired to the acquiring institution. In 2.0, a streamlined process, completed entirely within the system, will allow institutions to seamlessly complete the M&A process and transfer all individual registrations. In this journey, Institution A has entered into an agreement to acquire Institution B, and is therefore responsible for managing the M&A process within NMLS. As only Account Administrators will have access to the M&A functionality, Henry and Cornelius will be performing all M&A required actions on behalf of their institutions. Preceding Journey(s) N/A Background: Transaction Entry Acceptance Individual Registrants Transfer Discussion point: What will SRR's involvement be in the M&A process? Will M&A require SRR review and / or approval? Human activity Attestation/ Payment System activity Version 2, Delivered 4/10/17 BULK Option to perform action in bulk Updates Subsequent Journey(s) N/A Institution A has entered into a publicly announced agreement to acquire Institution B, with the transaction closing in 90 days. Under the SAFE Act, institutions have 60 days from the transaction effective date to complete the transfer of individual registrations. User Experiences: Henry, Institution Account Administrator for Institution A, is responsible for managing the M&A process for his institution as only Account Administrators will have access to the M&A functionality in 2.0. Henry wants to get a head start on the process, and clicks on the M&A link from his dashboard. Henry is prompted with questions to determine if this is truly an M&A action. If so, a guided wizard begins to walk Henry through the process. Henry indicates he works for the acquiring institution. Henry searches for and selects Institution B as the institution being acquired, enters the transaction effective date and other details of the transaction, and can also enter any notes for Cornelius, the Institution Account Administrator for Institution B. Cornelius receives a task on his dashboard indicating that Institution A has initiated an M&A action and selected Institution B as the institution being acquired. Cornelius accepts the action. Henry immediately gains access to view all of Institution B's records in the system as well as the full list of individual registrants employed by Institution B. The system prompts Henry with a question to determine if he would like to acquire all of Institution B's employees or select specific employees. In this scenario, Henry acquires all employees from Institution B and initiates payment for the M&A processing fees using the payment information stored in the system. BULK The system sends employment change requests to all individual registrants at Institution B. The notification provides details of the M&A action and tells them that their employer, employment record, and federal registration will be updated on the transaction effective date. The registrants can accept the request, or decline if they do not plan to continue their employment. As the individual registrants accept the requests, Henry gains limited access to their records. Henry tracks the acceptances on his dashboard. On the transaction effective date, Henry receives a task to confirm and attest that the acquisition is still closing that day. Once confirmed, the system processes the payment for the M&A base processing fee and all of the employment change fees for the individuals who accepted. The employer and employment record is updated for all of the individual registrants who accepted the employment change request. In addition, their federal registration is updated with the new employer. The records for Institution B and any affiliates that were also acquired are end-dated and can longer be updated, and Institution B's registration is cancelled. Any individuals who do not accept the employment change request in time will be required to go through the full employment change process including a background check to have their registration updated with the new employer. Henry I can restrict who has access to the M&A functionality within my organization. Henry I can complete all aspects of the M&A process within the system. Henry I don't have to contact the NMLS Call Center to initiate the M&A process. Henry The system walks me through the M&A process step-by-step. Henry I can enter an effective date in the future when completing the M&A process. Henry The system initiates the employment change requests for me, so I don't have to take any additional steps. Henry I can pay for employment change fees in bulk by adding multiple registrants to a single invoice. Henry The system automatically updates my acquired registrants' employer, employment record, and filing. 82

85 #24 - Mergers and Acquisitions (M&A) (Federal) NMLS 1.0 Pain Points: M&A does not allow for future dating. M&A does not update any of the record information except employment address. A separate process is needed to update the employee demographic information for M&A activity. M&A needs to be manually accomplished using excel data files and bulk data fixes. The process to initiate M&A is completely manual and done outside of the system. Institutions must contact the NMLS Call Center to obtain the Merger and Acquisition Request Form to start the M&A process. There is a lack of M&A functionality in 1.0. Institutions have to wait for SRR to provide access to the M&A functionality before they can start the process. Regulators are unable to formally review M&A within the system. NMLS 2.0 Capabilities: Ability to make multiple payments in one invoice similar to a shopping cart concept Ability to remove access to legal entities after leaving an entity either from termination or change in employment Ability for company user to send bulk s notifications with the same issue to do something (i.e., accept employment request) Ability to generate an invoice with multiple items. Ability to view a MLOs record for periods employed (even if individual is no longer an employee) Ability to send multiple notifications to different parties when actions are taken (e.g. M&A action). Notifications will be logged in audit trail. Ability to pay invoices on behalf of other users (in bulk) - e.g. company user pays for all company's employees invoices Ability to have role-based security access Ability to function as a real-time system where changes are reflected throughout the application immediately. Ability to track all actions, activities, and changes with an audit trail (e.g., who, what, when, why). Ability for users to assign roles and permissions Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials Ability to assist users with a step in the process based on the stage of the process and also on a page (i.e., context-aware help guides and videos to assist people with the process) help resources should be right on the page Ability to request account access from an individual Ability to have a single login/profile, with access and association to multiple entities. And the ability to identify and change what entity you are working on currently and all entities that you have access to in the system. Ability to check submitted forms for completeness against requirements and provide immediate user feedback on gaps/ errors/omissions Ability to easily toggle between one entity and another for which the user has an admin or organization role. Ability to combine logical workflow components to facilitate the user experience and reduce confusion/duplication (e.g. pay for employer change fees at the time of attestation) Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed Ability to initiate tasks based on user actions, another user's actions (who create a task for you), or system generated activities Ability to automatically update object record data when actions are taken on that object (e.g. update employment record when hired / terminated / transferred) Ability to assign tasks to individuals/groups 83

86 NMLS 2.0 Journey Map Engagement Journey Map 24 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Federal Registrants M&A process appears much improved, but there needs a clarification for the last two points... On the effective date of the merger, as the journey is written, it is unclear if those MLOs who have not yet accepted the M&A will still have 60 days post merger (legal day one) to use the M&A process to transfer their registration, or if once the merger is certified as having taken effect the employees from Institution B will need to use the process for new employees to register - kindly clarify Thanks for the feedback. We'll validate the requirement when we begin the detailed requirement for M&A. Flagged for Future Response 84

87 #25 - Using Consumer Access Personas: Journey Map Mary Individual Licensee Brett Consumer Sam Regulator Account Administrator (State) Research Background: This journey provides an overview of the various ways that Consumer Access will be used in 2.0. The journey focuses on the experiences of Brett, a consumer, who is currently in the market for a financial services company and utilizes Consumer Access to find licensees in his area. This journey highlights various capabilities that exist for Brett, including: submitting complaints, accessing disciplinary and enforcement actions, and researching companies/institutions and individuals in various financial services industries. Consumer Access is an important tool for finding information on financial services companies, and the revamped site will allow users to easily search and find information on participants in the mortgage, consumer finance, debt, and MSB industries. Human activity System activity Consumer Complaint Version 2, Delivered 4/12/17 BULK Option to perform action in bulk Preceding Journey(s) N/A Subsequent Journey(s) #26 - Consumer Complaints Brett is in the market for a financial services company and visits Consumer Access to research licensees in his area. He enters his zip code in the search field and the system returns search results for all companies and licensees conducting business within that zip code. Brett chooses a company, and clicks on Mary, a licensee for the company, to view her profile. Displayed on Mary's profile are all of her state licenses as well as any disciplinary or enforcement actions against her. Brett confirms that Mary is authorized to do business in his state and jots down her contact information. Brett gives Mary a call and tells her that he found her information on the NMLS Consumer Access website. He also tells her that he is in the market for a financial services company. After a brief conversation, Brett decides to start working with Mary. Over the next few months, Brett continues working with Mary to meet his financial services needs. However, during one of their meetings, Brett witnesses Mary engaging in unethical behavior and decides to end the relationship. Brett decides to submit a consumer complaint through the Consumer Access website to prevent this from happening to another consumer. Brett navigates to the Complaints section of Consumer Access and initiates a complaint. The system prompts him to create an account by filling out a brief form. By doing so, Brett will have access to his complaint later should he wish to edit it. Brett enters Mary's name in the search field, selects her name, and fills out the required information, such as providing a narrative of what happened. Brett submits the complaint, and it is routed to Sam, the Regulator Account Administrator, in Brett's state. (See #26 - Consumer Complaints journey for more detail). Brett can tailor how the complaint is submitted, for example, submitting anonymously. User Experiences: I am able to use the Consumer Access website to research entities and individuals in my area. The Consumer Access search functionality is user friendly and allows me to customize the search criteria to find exactly what it is I am looking for. I can search by industry, including mortgage, consumer finance, debt, and MSB. Brett Brett Brett Brett The contact information contained on Consumer Access is accurate and easy to find. I can access the Consumer Access website from my mobile device. If I have a question while using the site, help resources are available directly on the page. Brett Brett Brett I am able to submit a complaint against an entity or individual on the Consumer Access site and the complaint is automatically routed to the appropriate regulator. Brett I am able to quickly view any regulatory, disciplinary or enforcement actions on a profile page of a company or individual. 85

88 #25 - Using Consumer Access NMLS 1.0 Pain Points: The current website has a clunky search function, requires improvement to the look and feel, must make information easier to find, and improve ways to present the information. Search functionality is not user-friendly and makes it difficult to find what the user is looking for. Consumers looking for a particular company or lender should be able to filter on their search results. Consumer Access shows trade names tied to company right away, even if not approved. No distinction between major and minor regulatory actions. The Turing test appears too often requiring users to log in again, making the site very cumbersome to navigate. Not enough awareness of Consumer Access as a research tool. Help resources are difficult to find on the Consumer Access website. Non-mortgage companies are displayed in the same area as mortgage companies. Not all states require licensure in NMLS or to be licensed at all, resulting in inability of consumers to find complete information on a company. The Consumer Access view shows last company in the company field even if no longer employed by company. Unable to respond to regulatory actions listed on the site. The current process to submit a consumer complaint is not standardized across states License status dates can be manipulated. (Backdating wreaks havoc on NMLS Consumer Access/B2B). When an employment record is updated, the change does not flow through to Consumer Access. NMLS 2.0 Capabilities: Ability for consumers (public) to search NMLS entities and licenses for data made publicly available. Ability for consumers to submit complaints on an NMLS entity to state regulators. Ability for B2B users to access data downloads through consumer access portal. Ability to attach documentation to a complaint. Ability to submit a complaint via a mobile device. Ability to see how many complaints a licensee has had in other states. Ability to communicate with other users within the system. Ability to function as a real-time system where changes are reflected throughout the application immediately. 86

89 NMLS 2.0 Journey Map Engagement Journey Map 25 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry The only question we have on this Journey map is when would the complaint show in Mary's Consumer Access Profile? Will it be visible before the regulator investigates the complaint? When the complaint is entered is Mary's company notified? Details on consumer complaints still need to be worked out but we would envision there would be some sort of process for vetting complaints before they get posted to Consumer Access. Flagged for Future Response Industry Regulator The system returns search results for all companies and licensees conducting business within that zip code that is input by the consumer. Is the system looking for licensed locations in the same zip code, or for companies that are licensed to do business in the state where the zip code is located? For example, Vermont has very few licensed locations in the state, but there are plenty of licensees that can provide services here. Consumer Access would be starting to turn into Yelp Good feedback and we'll see what we can do to with the reviews. Licensing does not believe ensure CA does not turn into Yelp. complaints should be accessible to the public for a plethora of reasons. Borrowers and other individuals can place invalid complaints on LOs. This could possibly give borrowers a chance to submit complaints that allow them to get their way in a sense, then with the edit feature possibly be persuaded by the LO to edit or remove the complaint. Unethical actions could possibly arise from this. We'll address this more in detail once we begin the details requirements on Consumer Access. Regulator Regulator I thought about this zip code issue too. What information will be available to the consumer when a particular company is selected? Such as main location, branches, how long licensed in that state, regulatory actions of this licensee in other jurisdictions...? Step #5 The system should allow a state to have the option to let a consumer make or not make changes to a complaint that has been submitted. Otherwise, this becomes an evidentiary and complainant credibility issue for a state regulatory agency. We'll address this more in detail once we begin the details requirements on Consumer Access. Noted. 87

90 #30 Periodic Reporting (MCR) Personas: Background: Journey Map Jim Company Account Administrator (State) Sam Regulator Account Administrator (State) This journey captures the user experiences associated with preparing and submitting periodic reports via the system. Specifically, this journey covers the submission of the Mortgage Call Report (MCR), which consists of activity-based reporting for mortgage originators, and is required to be submitted per the SAFE Act. The two personas highlighted in this journey are Jim, a Company Account Administrator responsible for submitting the MCR, and Sam, a Regulator Account Administrator responsible for reviewing the MCR. Some of the key capabilities featured in this journey include: dynamic report display driven by business activities, bulk upload submission, ease of document upload (validation on multiple file upload types), document tagging with metadata, company document storage, version history of uploaded documents, configuration of expiration dates for saved uploads to personal/company profiles, and built in completion checks that avoid reporting errors. Human activity System activity API API Gateway Version 2, Delivered 4/14/17 BULK Option to perform action in bulk Notification Preparation Submission Review Preceding Journey(s) Subsequent Journey(s) N/A N/A The system notifies Jim that the MCR is available for him to complete. Company users will only see reports specific to their company based on the business activities provided during account creation. In this scenario, Jim's company holds a mortgage license, so he is notified when the MCR is available. He clicks on the link in the notification and a guided process begins to walk him through the report submission. invoice. User Experiences: Jim I am able to view the onscreen instructions to prepare to submit my report. Jim JIm has several options of submitting the report, including manual file upload, secure file transfer, or leveraging his company's API gateway. In this scenario, Jim uses the API gateway which interfaces with his internal systems to transfer the required data for the report. He follows the on-screen guide to create and submit the report. BULK API I am presented with a list of resources to help me prepare for my report submission (i.e., practice sheets, applicable definitions, etc.). Jim The system provides data validations and specific warning messages if there are any issues during the upload process, and also runs a completeness check. In this case, a specific error is identified with the data. This guided process also provides FAQ's and on-screen help resources along the way to help Jim correct the issue. I am able to utilize the help button on any page that I am on to review the functionality available to me on that given page. Jim I am prompted by the system when a report is made available for me to submit. Jim follows the FAQ's to address the issue directly on the screen and the system initiates the various validations again. No issues are found, so the system creates the report components, which Jim attests to and submits the report. Jim Sam receives a task on his dashboard once the MCR has been submitted. The system identifies any flagged items for Sam (e.g., explanatory notes, data mismatches, inconsistencies, or abnormal total amounts). He follows up with Jim for more information, or adds action items, if needed. If Jim had submitted the report past the deadline, the system would also generate a late fee The system walks me through a guided process to submit my report. Jim I receive a specific error message when there is an issue with the upload. Jim I am provided with the option to manually input or use a data upload option for the MCR reports. Jim I am able to upload my MCR data in multiple formats (e.g., XML, CSV). Jim I am able to amend or make changes to a MCR after uploading. Jim I am able to make corrections in the system without having to upload the file again. 88

91 #30 Periodic Reporting (MCR) NMLS 1.0 Pain Points: Call center cannot see screen to assist users which prevents them from being able to answer detailed definition questions about the reports. User interface is outdated. System times out during upload process. Logic behind report creation is not 100%. Challenges exist due to different legal entities and business models (e.g.., determining what fields to fill in and are applicable for each business model) Ripple effect of changes in MCR or to MCR (e.g. to/from HMDA) based on state findings etc. The Licenses per state cap forces some companies to execute multiple uploads. Changes to MCR just overwrite with no history of what changed, creates challenges if you were to have to go back and review. No customizable reports (ability to add/remove columns as needed) No ability for reports being available on any page with results/list of MLO records or invoices (i.e., recap of page specific detail) Currently creates major challenges for reconciliation and tie-outs. The reporting of zeroes (e.g., no activity MLOs; terminated on first day). Failure during upload without any specific error messages. The amount of time it takes to create a file and upload is too long. No customization of report (business case for keeping standard vs. expanded). Parts of the report are outdated, all fields not being utilized. Financial Condition (FC) component not aligned to GAAP. Difficult to manage guidance on the report. XML upload is not an ideal solution for smaller companies. No wizard functionality exists, lack of understanding on how to complete MCRs (system timeout issues with MCR). NMLS 2.0 Capabilities: Ability to accept multiple file types. For example: [Doc upload] jpg, pdf, doc, xls [Periodic Reporting] csv and xml. Ability to perform file validations on uploaded files. Ability to indicate what fields are required prior to entry and after form submission (if required fields were omitted). Ability for error comments to be specific (in line help and during periodic reporting uploads). Ability to assist users with a step in the process based on the stage of the process and also on a page (i.e., context-aware help guides and videos to assist people with the process) help resources should be right on the page. Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to configure an expiration date for saved uploads to personal or company profile (documents uploaded as part of filings will follow record retention rules). Ability to upload multiple files at one time. Ability to upload documents without file size limits. Ability to show and access version history of uploaded documents. Ability to tag documents with metadata in the document upload section based on workflow and context. Ability for documents uploaded to NMLS to be scanned for viruses prior to submission. Ability to store company documents in a central location. Ability to limit access to sensitive documents/data in the system by group/user. 89

92 NMLS 2.0 Journey Map Engagement Journey Map 30 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Flagged for Future Response Industry Industry For this journey map of the MCR functionality, the 2.0 capabilities sound great! Curious if more information about what content is changing on the report, what will stay and what will be eliminated? Will reports be customized to a company s license types? Map #30 - the first step indicates that the company will only see reports based on the business activities. We currently have a client that is a consumer lender and this is indicated in the NMLS; however, they are required to file quarterly MCRs because they hold licenses that may require these reports. Is this going to be fixed so that this company is no longer required to submit these reports? Also, because this company is not a mortgage lender some of these licenses do not require audited financial statements for consumer lenders. This information should also be distinguished in NMLS 2.0. For starters, we do anticipate that reports will be "customized" based on a company's business activities. We are rolling out a MCR revision plan and will engage starting early June with industry on this. This should be addressed/fixed in 2.0. Industry Staff There should be an Export feature that allows the analyst to export what they have uploaded into the MCR. This will minimize the human errors when the MCR information is copied and pasted into another document. In regards to the MLO section of the MCR- the 750 cap for uploads should be raised or there should be an option to upload the data into two separate groups of 750 MLOs so it should eliminate the use of manual entry. E.g. California has a much larger amount of MLOs that surpass the 750 cap. Anything over 750 has to be inputted manually by the analyst. Pro: A Zero is added for MLOs who were termed on their first day. Step 4 - Minor adjustment needed. The step indicates the system creates the report components but the components would have already been created back in step 1 or 2 because the system will already know what components each entity is required to complete based on their business activities. Good feedback. Noted. 90

93 NMLS 2.0 Journey Map Engagement Journey Map 30 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator In Step 1, Jim is presented with components of the MCR relative to business activities (BA) selected in the MU1. Question: Will state-specific RMLA components be presented to Jim based on BAs selected by state? Example: If Jim had selected 'Mortgage Servicing' as a BA for Kansas but not for Nebraska, will Jim be presented with servicing components for its Nebraska RMLA piece of the MCR? I suppose the best way might be to present Jim with all servicing fields for all states where a license is held, that way, if servicing is conducted, but Jim neglected to mark Servicing for Nebraska in his MU1, then the state can at least get the data and then follow up on any discrepancy in BA selections. Or else, it could offer the MCR fields for each state but only require the fields if the MU1 contains a BA selection by state for that component. We have not started the requirements for MCR yet, but will circle back on this once we do. Flagged for Future Response X 91

94 NMLS 2.0 Journey Map Engagement Journey Map 30 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Step #1 - We have had significant problems with Noted. This can be addressed as part of agency company MLOs not being able to submit certain settings. reports because the system did not make it available. In the Journey Map, I would request that the system still notifies Jim that the MCR is available for completion, but that the other reports are still available if he is required to submit them (such as reports that were due during a time he was Approved-Inactive). Step #1 The state should be allowed to set who is allowed to submit the MCR. For example, California BRE requires that the Qualified Individual submit the report, but the system allows it to be almost anyone with account access. Step #3 The system should allow a state to have the option to let their licensees make or not changes to a Mortgage Call Report. We have had problems with company MLOs changing MCRs so many times we don t know which is the correct report. And it takes away from the fact that the submitter has to attest to the truth and accuracy of the reports if they re able to change them as many times as they want. Step #5 - The late fee invoice generation should be a function that a state may elect or not elect to use. Flagged for Future Response 92

95 #31 - Reporting, Data, and Analytics (Company/Institution) Personas: Journey Map Background: This journey captures the experiences of, a Company Organization User (State), using NMLS 2.0 to view reports, access data, and utilize data analytics tools. Both state-licensed companies and federally-registered institutions have a great need Kim for reporting, data, and analytics from the system, however, in the current system, there is a lot of pain associated with these functions Institution Organization User and entities have difficulty accessing timely, relevant, and useful information. These entities typically require information to support exams, assist in accounting and budgeting, manage business operations, ensure employee information is up-to-date, and confirm that all (Federal) licensees/registrants are in compliance with regulations and the SAFE Act. This journey explores the various capabilities that users will have in 2.0 to meet their data and reporting needs. For reporting, users will be able to access relevant canned reports with the ability to filter and sort, and use a self-service, easy-to-use interface to create ad hoc reports and customizable datasets. For data, entities will be Company able to leverage an API gateway to download data from the system, or choose from different delivery options to receive datasets. Finally, Organization User for analytics, users will have a tool for advanced visualization and analysis for more sophisticated data exploration. (State) Human activity Version 2, Delivered 4/12/17 System activity API API Gateway Definitions: Reporting - Use of dashboards in the user interface that display summary metrics and information, canned and ad-hoc reports Data - Ability to export tables out of NMLS, including standard tables but also providing the ability to filter on certain attributes Analytics - Use of a separate analytics dashboard that provides advanced visualizations, trends, and historical analysis for insights into an organization's operations BULK Option to perform action in bulk Preparation Reporting Data Access Analytics Preceding Journey(s) Subsequent Journey(s) N/A N/A is responsible for accessing reporting and data from NMLS in order to support and manage his company's business operations. In addition, leverages the analytics tool within NMLS to perform more advanced data analysis. Renewal season is approaching and wants to make sure his licensees are meeting their continuing education (CE) requirements, and that action items on any company, branch, or individual licenses are being addressed. User Experiences: clicks on a link from his dashboard to take him to the reporting interface. From here, can access a variety of relevant, timely and useful canned reports. The reports allow to access information on accounting, workload, license status, open items, etc. pulls a report showing CE requirement completion for each licensee, and another report showing a list of all open action items and an aging chart. finds the reporting interface to be very intuitive and easy-to-use. He can download canned reports, and also search, filter, sort, and drill down on the reports as he chooses. He can save any reports he plans to use frequently and run them over and over again in the future, in addition to auto-scheduling reports. also wishes to create some ad hoc reports to support a special project he is working on. An ad hoc report is a unique request that can't be satisfied by the existing variety of options. The self-service interface allows him to create a customized report, pay a fee, and choose the delivery method for the report (e.g. , download, secure transfer). For complex ad-hoc requests, the request is reviewed, processed and handled by the Internal Support Team. Over the course of the renewal season, continues to access useful process reports which show how many filings have been submitted, approved, rejected, etc. He can use the information in the reports to identify open items and follow up with users to complete these items. 's company is notified that they are being examined at year-end. will need access to all historical information on his licenses for the last two years, including employees who have left the company. leverages his company's API gateway to access all of the relevant information for the last two years. The data is based on a wellstructured data model that includes all historical information. API The examiner requests additional data on a subset of the company's licensees that is contained within NMLS. navigates to his reporting dashboard, where he can self-serve and access several useful datasets. He can customize the datasets before download by filtering the data as he chooses. At the end of the year, wants to run some advanced analytics on his company's Call Report. clicks on a link from his dashboard to take him to the analytics tool. The analytics tool provides advanced visualization and analysis for more sophisticated data exploration. The reporting tool allows me to gain insight into my company's operations and take action on open items. The canned reports provided in 2.0 provide real-time data and contain relevant and useful information. I find the reporting interface to be very intuitive and easy-touse. I can search, filter, sort, and drill down on the reports as I choose. uses the tool to spot trends and patterns, which ultimately help him gain greater insight into his company's licensing activities and improve operations moving forward. I can save any reports that I plan to use frequently and run them over and over again in the future. The self-service interface allows me to create customized, ad hoc reports. I can access all historical information for my company, including information on prior employees from the time they worked here. I can leverage my company's API gateway to access a daily dump of data from the system. The analytics tool allows me to gain greater insight into my company's licensing activities by showing trends and patterns in the data. 93

96 #31 - Reporting, Data, and Analytics (Company/Institution) NMLS 1.0 Pain Points: There is no ability for customization of reports or ability to customize datasets. Strong reliance on ad hoc reporting as standard reports do not always provide relevant information. Reports/analytics do not contain real-time data. Reports do not come in user-friendly formats (CSV format vs. Excel with totals, averages, etc.) There is a lack of granularity within NMLS reports. Unable to analyze workflows within NMLS. Certain states use their own system on a lag (with SRR s data download) which create data timing mismatches that cause challenges during exams. NMLS does not have a built-in reports interface for reporting on renewals, work items, license applications, sponsorships, and so on. Process of reviewing Renewal Analytics (currently external to system - Qlikview) is challenging. Data contained in reports are sorted in a logical order - agencies that download reports must reprogram when new columns are added. Lack of reporting capabilities on my licenses. (inability to see which other states our control persons have authorized to view their CBC results). Call reports cannot be exported from the system. Manual process to pull reports, review reports and send s. Work item analytics: Inability to report in Qlikview without flexibility is a problem as 90 percent of request are ad-hoc. Need a report with licensing estimate/forecast support to allow understanding of investment per person, renewal costs, YTD spend. Historical data not available for terminated/separated employees despite 2 year exam lookback. Single system of record does not exists with uniform data regardless of data downloads: Data mismatches between state regulator, reports provided to company, and company systems. Unable to provide regulator reports for exam purposes (to prevent data disputes). This would reduce the amount of data companies are required to provide. NMLS 2.0 Capabilities: Ability to extract data from NMLS in usable formats (e.g., CSV, delimited., etc.) Ability to upload data files from company HR systems to perform a validation against data in NMLS (reconciliation between HR systems and employees' NMLS records). Includes workflow and processing to compare uploaded data to NMLS data and provide a screen to decide which version to apply to NMLS (keep/ overwrite). Ability to select which fields from an available set of fields from NMLS that can be downloaded. Capability will be available to regulators and industry; however, extent of capability for industry and what is behind paywall depends on SRR requirements. Ability to secure data downloaded from the system to protect PII and other sensitive data Ability to generate a authenticated version of a company / LO license record from NMLS that could be used for adjudication. Printable version should include proper logos, labels, and all pertinent details and history. Ability to download large numbers of records without file size limitations Ability to prompt to filter reports before running reports (e.g. before running report, constrain time period for historical report) Ability to download data extracts without navigating through the website (for regular, recurring downloads) Ability to provide standard reports to support state examinations from NMLS Ability to interface NMLS with internal systems such as Human Resource systems, GL, Testing, Accounting, and Education Ability to expose licensing costs to companies to understand the cost per person, total renewal costs Ability to function as a real-time system where changes are reflected throughout the application immediately. Ability to view a MLOs record for periods employed (even if individual is no longer an employee) Ability to create customized reports in reporting tool based on available data fields Ability to save report settings and pull this report over and over again Ability to filter data in reports and list views Ability to access historical data Ability to sort data in reports and list views Ability to share a saved report with other system users Ability to drill-down to more granular details in reports Ability to display the reports in a non-editable format 94

97 NMLS 2.0 Journey Map Engagement Journey Map 31 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry This is exciting news! Curious if there will be similar data fields that are available today, or will some be eliminated? Still too early in the process to be able to answer this question. Certainly, we've heard companies would like access to more data and the ability to view it in different ways. Flagged for Future Response Federal Registrants #31 Reporting, Data and Analytics All steps on the map only refer to State user. Is there a separate map for federal? We acknowledge there will likely be unique reporting, data, and analytics requirements for institutional users. We'll define these more during the detailed requirements phase. 95

98 #32 - Reporting, Data, and Analytics (Regulator) Personas: Journey Map Background: This journey captures the experiences of Sam, a Regulator Account Administrator (State), using NMLS 2.0 to view reports, access data, and utilize data analytics tools. Both state and federal regulators have a great need for reporting, data, and analytics from the system, however, in the current system, there is a lot of pain associated with these functions and regulators have difficulty accessing timely, relevant, and useful information. Regulators typically require information to analyze their workflows, support Sam their filing reviews, support examinations, analyze consumer complaints, and confirm that all licensees/registrants are in compliance with Regulator Account regulations and the SAFE Act. This journey explores the various capabilities that users will have in 2.0 to meet their data and reporting Administrator (State) needs. For reporting, users will be able to access relevant canned reports with the ability to filter and sort, and use a self-service, easy-touse interface to create ad hoc reports and customizable datasets. For data, entities will be able to leverage an API gateway to download data from the system, or choose from different delivery options to receive datasets. Finally, for analytics, users will have a tool for advanced visualization and analysis for more sophisticated data exploration. Human activity Version 2, Delivered 4/12/17 System activity API API Gateway Definitions: Reporting -Use of dashboards in the user interface that display summary metrics and information, canned and ad-hoc reports Data - Ability to export tables out of NMLS, including standard tables but also providing the ability to filter on certain attributes Analytics -Use of a separate analytics dashboard that provides advanced visualizations, trends, and historical analysis for insights into an organization's operations BULK Option to perform action in bulk Preparation Reporting Data Access Analytics Preceding Journey(s) Subsequent Journey(s) N/A N/A Sam is responsible for accessing reporting and data from NMLS in order to support and manage his agency's filing reviews and operations. In addition, Sam leverages the analytics tool within NMLS to perform more advanced data analysis. Sam's agency is in the midst of renewal season and Sam wants to view operational reports to see how his staff is managing their workload. User Experiences: Sam Sam clicks on a link from his dashboard to take him to the reporting interface. From here, Sam can access a variety of relevant, timely and useful canned reports. The reports allow Sam to access information on accounting, workload, licenses statuses, open items, etc. Sam pulls reports that show a variety of operational metrics, such as cycle times for task completion, # of open tasks, # of deficiencies, past due items, # of filings received, etc. Sam finds the reporting interface to be very intuitive and easy-to-use. He can download canned reports, and also search, filter, sort, and drill down on the reports as he chooses. He can save any reports he plans to use frequently and run them over and over again in the future, in addition to autoscheduling reports. Sam also wishes to create some ad hoc reports to support a special project he is working on. An ad hoc report is a unique request that can't be satisfied by the existing variety of options. The self-service interface allows him to create a customized report, and choose the delivery method for the report (e.g. , download, secure transfer). Sam's agency also needs to load the various types of data that are housed within NMLS into its internal systems, including data on examinations, complaints, and Call Reports submitted by companies. Sam leverages his agency's API gateway to access all of the relevant data that his agency needs. The data is based on a wellstructured data model that includes all historical information. On a periodic basis, Sam uses the API gateway to pull all examinations data and Call Report data into his agency's internal system. The examination data includes exam dates, examiner, next follow-up, exam fee, follow-up letter, examination response, and legal review. Sam also receives a request from an examiner for complaints data on a certain entity. Sam navigates to his reporting dashboard, where he can selfserve and access several useful datasets. He can customize the datasets before download by filtering the data as he chooses. At the end of the year, Sam wants to run some advanced analytics on his agency's cycle times. Sam clicks on a link from his dashboard to take him to the analytics tool. The analytics tool provides advanced visualization and analysis for more sophisticated data exploration. The reporting tool allows me to gain insight into my agency's operations and take action on open items. Sam Sam The self-service interface allows me to create customized, ad hoc reports. The canned reports provided in 2.0 provide real-time data and contain relevant and useful information. Sam Sam I can access data that my agency needs on examinations, complaints, and Call Reports. API I find the reporting interface to be very intuitive and easy-touse. Sam API Sam I can leverage my agency's API gateway to access a daily dump of data from the system. I can search, filter, sort, and drill down on the reports as I choose. Sam Sam The analytics tool allows me to gain greater insight into my agency's licensing activities by showing trends and patterns in the data. Sam uses the tool to spot trends and patterns, which ultimately help him gain greater insight into his agency's workflows and improve operations moving forward. In addition, Sam can receive comparison data for other state agencies to see how his agency compares. I can save any reports that I plan to use frequently and run them over and over again in the future. 96

99 #32 - Reporting, Data, and Analytics (Regulator) NMLS 1.0 Pain Points: There is no ability for customization of reports or ability to customize datasets. Strong reliance on ad hoc reporting as standard reports do not always provide relevant information. Reports/analytics do not contain real-time data. Reports do not come in user-friendly formats (CSV format vs. Excel with totals, averages, etc.) There is a lack of granularity within NMLS reports. Manual process to pull reports, review reports and send s. There is no backward compatibility - changes are in effect as of the release date. Unable to analyze workflows within NMLS. Data contained in reports are sorted in a logical order - agencies that download reports must reprogram when new columns are added. NMLS does not have a built-in reports interface for reporting on renewals, work items, license applications, sponsorships, and so on. Work item analytics: Inability to report in Qlikview without flexibility is a problem as 90 percent of request are ad-hoc. The external analytics interface (currently Qlikview) cannot link its analysis back to the system. For example, a list of outstanding work items does not link back to the system to allow a regulator to view the details of that work item. Process of reviewing Renewal Analytics (currently external to system - Qlikview) is challenging. Regulators who need access to the analytics tools usually have to wait at least one day for access to be granted, since access is granted as part of a lengthy data refresh that synchronizes user accounts between the two systems The data analytics environment receives a nightly data refresh from NMLS. This means that a regulator must wait a day to see their work in the system reflected in the analytics tools. Call reports cannot be exported from the system. Agencies have no say in the data they get in the report (canned reports in system). Automatically default in an excel file (zip codes starting with zero it disappear) NMLS allows regulators to view a web page form of MCR filings, but does not provide a data export feature that allows regulators to do analysis on the data or upload them into their own systems. Historical data not available for terminated/separated employees despite 2 year exam lookback. Certain states use their own system on a lag (with SRR s data download) which create data timing mismatches that cause challenges during exams. Single system of record does not exists with uniform data regardless of data downloads: Data mismatches between state regulator, reports provided to company, and company systems. Many agencies cannot handle sync files (vendor solution of choice) when there are issues with data. Daily business functions are impacted when download files are late. Releases are implemented into production with errors/issues. (Issues are sometimes misses during testing; schemas do not always match the Data Specification). States use data download to support their reporting requirements due to lack of granularity with NMLS reports. Agencies have no say in the data download development process - they receive notification on how the download will change. NMLS 2.0 Capabilities: Ability to extract data from NMLS in usable formats (e.g., CSV, delimited., etc.) Ability to select which fields from an available set of fields from NMLS that can be downloaded. Capability will be available to regulators and industry; however, extent of capability for industry and what is behind paywall depends on SRR requirements. Ability to secure data downloaded from the system to protect PII and other sensitive data Ability to provide standard reports to support state examinations from NMLS Ability to download large numbers of records without file size limitations Ability to display the reports in a non-editable format Ability to download data extracts without navigating through the website (for regular, recurring downloads) Ability to prompt to filter reports before running reports (e.g. before running report, constrain time period for historical report) Ability to interface NMLS with internal systems such as Human Resource systems, GL, Testing, Accounting, and Education Ability to share a saved report with other system users Ability to function as a real-time system where changes are reflected throughout the application immediately. Ability to upload data files from company HR systems to perform a validation against data in NMLS (reconciliation between HR systems and employees' NMLS records). Includes workflow and processing to compare uploaded data to NMLS data and provide a screen to decide which version to apply to NMLS (keep/overwrite). Ability to create customized reports in reporting tool based on available data fields Ability to filter data in reports and list views Ability to sort data in reports and list views Ability to drill-down to more granular details in reports Ability to access historical data Ability to save report settings and pull this report over and over again 97

100 NMLS 2.0 Journey Map Engagement Journey Map 32 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Regulator Map # 32 - Excited about the option for ad hoc reporting. Step 5 - For canned reports, it would be nice to be able to filter and sort the pre-selected fields prior to generating the report, and also save those selections for future downloads. Thanks! We will make sure you are part of that detailed conversation on this as we proceed if you'd like. Noted. Flagged for Future Response Staff Regulator Regulator This journey seems to include data download Noted and we'll discuss with PwC. functions when we say on a periodic basis Sam uses the API gateway to pull data from NMLS into their system. The beginning of the journey we only mention that Sam wants to see how his staff is managing renewals but in the Data portion we mention Sam wants to download call report and examination data. I think it might be best to pull the download aspect out of here and only focus on reports and analytics. In Step 4, reports are pulled based in part by past Noted. due items which indicates Sam s staff had set a due date on a license item perhaps. Currently, the due dates are not mandatory when setting license items, which creates holes in the Reminders functionality of the current system. Sam needs to be able to configure whether or not his staff is required to set due dates on items, allowing consistent followup. In Steps 8-9, Sam uses an API to pull bulk data from Noted. NMLS to the state system. I don t know if this is the map to comment on or not, but Sam also needs an ability to push bulk data TO the NMLS from the state system, similar to the Regulator Log Upload File current capability. Example data that could be pushed in bulk to NMLS would be the state license numbers, original license dates, and generic license items (type, text, due dates) to multiple records simultaneously.. 98

101 #33 - Surety Bonds Management Personas: Journey Map Janet Surety Producer Account Administrator Company Organization User (State) Chester Surety Company Account Administrator Account & Entity Creation and Setup Background: This journey gives an overview of how the electronic surety bond process will work in 2.0, and captures the experiences and interactions of Chester, Janet, and as a surety bond is created, executed, and delivered to the regulator. Key aspects of the process include: account creation and validation, creating and managing associations between surety companies and producers, licensees granting authority to create bonds on their behalf, using a guided wizard to create and sign a bond, making corrections to a bond, licensees reviewing and signing a bond, and bond execution and delivery to a regulator. The journey also details processing a broker of record change, executing surety bond riders, and converting paper surety bonds into electronic format. Please note that bond term negotiation is an offline process and is out of scope for NMLS 2.0 at this time. Creating Associations Human activity System activity Version 2, Delivered 4/12/17 BULK Granting Authority Option to perform action in bulk Preceding Journey(s) Subsequent Journey(s) Chester and Janet are Account Administrators at a surety company and surety producer, respectively, that do business in a state moving to electronic surety bonds only. They have never used NMLS before, so they go to the NMLS website to find a clearly defined set of 'quick links' which includes setting up a new account. User Experiences:? Janet clicks the button to create a new bond, and a guided wizard begins to walk her through the process. Janet selects 's company as the licensee, enters the appropriate license type, and populates the rest of the core data that is required (e.g. state, bond #, limit, underwriter, etc.). If there are state-specific requirements, Janet is prompted to enter these as well. Chester Janet N/A They are asked a series of questions to guide them to the right account type to register for, in this case Surety Company/Producer Account Administrator, and are asked if this is for a new entity in NMLS. They are prompted to input basic information about themselves and their entities (e.g. SSN and EIN) for validation. The system automatically validates my personal and company information and creates an account for me. Janet Janet reviews the information that she entered, signs the bond as the company's designated signer, and sends the bond to for review. Chester The bond creation wizard walks me through the process of creating a bond step-by-step. The system validates Chester/Janet and their entities' basic identifying information against external data sources and against rules to prevent duplication (e.g. duplicate addresses). If there are no issues, the accounts and the new entity records are created. If there are any issues or red flags, the request goes to SRR for manual review. Note: Surety entities and their system users will not receive an NMLS ID unless they indicate they are also a licensee. Chester and Janet log into NMLS and complete their own personal profile information. In addition, they populate their company record with the required information, such as state authorizations, bonding limits, designated signers, etc. The system could also potentially validate the state authorizations and bonding limits against external data sources. Note: One user can manage multiple surety companies. Bond Creation, Execution, and Delivery receives a task on his dashboard that a bond is ready for his review. notices some of the data is incorrect, and initiates a request for corrections. could also decline the bond if any non-editable fields were incorrect (e.g. licensee), which would force Janet to create a new bond. Janet I can easily see all of my company's associations on one page and update any associations accordingly. Janet receives a task to make corrections. She corrects the data, re-signs the bond, and sends back to. Chester Janet I have the ability to request corrections to a bond if any of the information is incorrect. Chester clicks on a button on his dashboard to create associations with surety producers. He searches for and selects Janet's company to initiate the association process. The search and filter functionality allows Chester to easily find producers, and he can filter to only show producers who have the same state authorizations and sufficient bonding limits. Note: Producers will be notified of any updates made to the surety company information. BULK receives another task and reviews the updated bond. The information looks good, so accepts and signs the bond. The bond has now been fully executed. The bond is attached to the company's record as opposed to a license, allowing it to be attached to a new application for a license in the same industry if the license is ever terminated. The search functionality allows me to search for companies that have the same state authorizations and bonding limits as my company. The bond is attached to my company's record as opposed to a license, allowing it to be attached to a new application of the same license type if the license is ever terminated. Janet receives a task on her dashboard to accept the association with Chester's company. By accepting, her company now has the power to create and sign bonds on behalf of Chester's company. Janet could also decline the association if she wishes. BULK? 's company is applying for a license in the state where Chester and Janet's companies do business. He contacts Janet's company and decides to go with her company is presented with two options at this point. 1) If his A few months later, 's company company is already licensed and the new bond is for the decides they want a new broker on their same license, he immediately delivers the bond to the bond, and he initiates a broker of record regulator if required, 2) If his company is in the process of change. Chester receives a task, updates applying for a license, he indicates he does not want to the broker on the bond, and signs and deliver at this time. When initiates his company's sends the bond back to. receives a filing in the future, he selects the bond to attach it to the task, and reviews and signs the bond. Note: filing when he gets to that step in the process. Surety bond riders would follow the same process as executing a broker of record change. BULK I can delegate the power to I can find a surety company or create and sign bonds on my producer to issue a bond for my company's behalf to a company right in the system. producer right in the system. Chester I can easily attach a surety bond to my company's license filing. BoR Change Chester 8 9 clicks the link to go to the surety bond page. He searches for Janet's company, and clicks the button next to their name to grant them authority to create bonds on his company's behalf. Janet I can see a full list of the bonds my company has issued on my bond dashboard, and it is very easy to search for a particular bond. Janet receives a task to approve the authorization and accepts. Janet is responsible for creating the bond in NMLS, and gathers all of the required information from the producer sales representative who is working with 's company. Bond Conversion N/A 's company has a paper surety bond issued by Chester's company in a different state that is moving to electronic surety bonds. The state has issued a deadline to convert all paper surety bonds into electronic format. Chester and follow the same process of creating, signing, executing, and delivering the bond to the regulator that was discussed in prior steps. The bond is created and transferred as-is into the electronic format BULK I can easily grant authority to create bonds on my company's behalf and ensure the producer includes the appropriate license type. 99

102 #33 - Surety Bonds Management NMLS 1.0 Pain Points: Account Validation NMLS is unable to automate validation for the account requests and state authorizations and bonding limits. Bonding limits are not validated but changes currently require approval from an SU. Surety Companies require immediate updates to accommodate one off bond issuing. Once state authorizations are approved, the system does not check on an on-going basis to confirm the entity retains the required authorization with NAIC/NIPR. Presently, SRR/NMLS has no plan to do this manually. NMLS does not allow for surety entities to have branches or segment different business types, but they have expressed they do separate activities in different departments based on region or company size (East and West region, or commercial bonds and small company bonds). Associations are currently created and managed one off, however, often times a surety company will want to associate several of their underwriting companies to a single SBP. This requires them to duplicate the process for each of their underwriting companies and if there are changes (such as the SBP being approved in a new state) the SC must make separate updates to each association. SBP admins are able to make changes to the NPN for a representative which automatically populates with associations without approval from the SC. Currently, the feeling is that this isn t relied on heavily by the SC when creating the association, but as NMLS becomes more of the system of record, this will become a greater issue. The system does not validate authority for representatives, though the information may also be available from the NIPR. Bonds are currently attached to a specific license instance; if the license is terminated, it cannot be attached to a new application of the same license type. Likewise, if they hold two licenses under the same state agency, if the activity is a similar type, they should be able to have one bond cover both; not the case in NMLS ESB. Once surety bond authority is granted to a SC, it currently cannot be removed. SBPs can be removed if they are not the broker of record on any active or pending bonds. If a bond is created by a SC, NMLS currently does not allow the SC to sign a SBP (Broker of record). These bonds must be managed by the surety company. SCs and SBPs have a difficult time with the bond creation process, specifically when selecting the license type. Currently, surety bonds fall in more general buckets like mortgage or financial services and the surety entities are less familiar with what license type the principal holds. They do not have access to that info in NMLS. Also, since bonds can be created before a license application is submitted, any license type can be selected. This could be managed more easily with an intent function including a Requirements Check. This would only allow the surety entity to select a license the company holds or has indicated they plan to apply for. The bond management page is a list of bonds; it can be filtered, but once a single filter fills a page, it becomes more difficult to manage. The user profile for the Representatives (Attorney in Fact) are managed by the SBP admin since these are record specific user accounts. This creates a risk where an admin can change the address and reset the password allowing anyone to sign bonds as the representative. NMLS 2.0 Capabilities: Ability to track all actions, activities, and changes with an audit trail (e.g., who, what, when, why). Ability to view/generate a full or object-level audit trail (e.g. list of changes made to a company license record) Ability to publicly (within NMLS, not consumer access) notate the reason why a change was made and capture free form notes to further describe the nature of the change. Supports regulator review and ability for companies to identify the differences between and reasons for amendments/filings. Ability to dynamically require additional steps or uploaded document(s) based on pre-defined rules on fields such as license type and state Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to accept multiple file types. For example: [Doc upload] jpg, pdf, doc,.xls / [Periodic Reporting] csv and xml. Ability to upload multiple files at one time Ability to tag documents with metadata in the document upload section based on workflow and context. Ability to store company documents in a central location Ability to provide e-signature capability for any forms / documents requiring a wet signature Ability to check submitted forms for completeness against requirements and provide immediate user feedback on gaps/ errors/omissions (similar to Turbo Tax) Ability to indicate what fields are required prior to entry and after form submission (if required fields were omitted) Ability to send multiple notifications to different parties when actions are taken (e.g. individual is terminated by company, then individual, company, and regulator could all be notified). Notifications will be logged in audit trail. Ability to have role-based security access Ability for users to assign roles and permissions (delegated authority within parameters/capabilities granted in the admin dashboard by SRR) Ability to attach personal details to personal profile instead of to license, such that changing companies and getting a new license does not invalidate certain personal details (e.g. valid fingerprints carry over when changing companies and getting a new license/registration) Ability to initiate tasks based on user actions, another user's actions (who create a task for you), or system generated activities Ability to assign tasks to individuals/groups Ability to communicate with other users within the system Ability to combine logical workflow components to facilitate the user experience and reduce confusion/duplication (e.g. pay for renewals fees at the time at the time of attestation since many individuals do not attest, which results in overpayment in the current state) Ability to see progress while completing the filing. (progress bar) Ability to set regulator fees and other configurable license requirement and workflow settings. Workflow will require all changes to go through SRR review prior to going into effect. 100

103 NMLS 2.0 Journey Map Engagement Journey Map 33 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Map 33 in this process, it does not mention that must send the bond once reviewed for approval to a Executive Officer, will that still be required? This is a license specific setting. If required, it will route to an EO. We will make sure this is noted. Flagged for Future Response 101

104 #34 Workload Management for an Institution Personas: Journey Map Henry Institution Account Administrator (Federal) Institution Organization User (Federal) Ted Designated 3 rd Party User Matt Individual Registrant (Federal) Sandy Institution Organization User (Federal) Background: This journey highlights the user experiences associated with institution users (e.g., Account Administrators, Organizational users, etc. ) that manage their workload via their intuitive, configurable dashboard. Henry, an Institution Account Administrator, is overwhelmed with tasks during a recent surge of new employees needing to register and relies on his team (, Sandy, Matt, and Ted) to help the institution close out all open and aged tasks. Some of these tasks include submitting registrations for new prospective registrants and paying invoices. The core components of this journey include: completing and prioritizing tasks, assigning and reassigning tasks to other users within the system, managing and customizing the dashboard, notifying users of tasks and deadlines, and tracking operational metrics. Human activity System activity API API Gateway Version 2, Delivered 5/1/17 BULK Option to perform action in bulk Operational Metrics Task Re-assignment Task Creation Validate Roster Preceding Journey(s) Subsequent Journey(s) N/A N/A 8 9 Henry, an Institution Account Administrator, logs into the system to manage all registration tasks. From his dashboard, which provides an intuitive, user-friendly interface, he views all of the new and open tasks that have been prioritized based on his configuration settings, and any urgent tasks requiring his immediate attention. Henry analyzes the operational metrics from his dashboard to see how many outstanding items require immediate attention. After reviewing the large volume of aging tasks from his dashboard, Henry decides to assign these outstanding tasks to, one of the Institution Organization Users. He filters his worklist by outstanding tasks, selects each task and assigns them to to complete immediately while he continues to work through other urgent items on his dashboard. BULK is notified via with a link to direct him to his dashboard. He views the newly assigned tasks on his dashboard. He is tasked with submitting outstanding registrations for individuals. From his dashboard, he clicks on a link that takes him to the list of registrations; from there he takes action. More detailed information on the registration filing process can be found in journey maps #52, 53, and 54. Note: the system archives tasks that have been completed. A month ago, Henry created a task for Sandy to follow up with Matt, who has been struggling to clear a task. Sandy has not followed up yet as she is on vacation, so Henry uses search functionality to find the open task, updates the priority level to urgent, and re-assigns to. receives the task on his dashboard and sends Matt a follow up task to complete his outstanding task. Matt receives 's task and works with him directly to resolve the task. Once this is completed, can now submit the new registration filing on his behalf. Matt attests to the filing that was initiated by, and pays for and submits the filing to close out the task on his dashboard. Henry assigns another task, this time to Ted, a Designated Third Party User, who was hired to help Henry's institution manage the registration process throughout the year. He provides Ted with a task to complete registrations for some new employees. Ted logs into NMLS and is taken to his dashboard; he has several other clients as well, and from this one centralized dashboard, can toggle back and forth between all of the entities that he works on. Ted selects Henry s institution from his drop-down menu, and he sees the new task on his dashboard. Ted initiates the filings and is guided through the filing process step-by-step. Once the filings are complete, he sends to Henry to attest and submit. After confirming that all eligible registrations were submitted and all open tasks were closed, from his dashboard, Jim periodically validates the institution roster to ensure all individuals affiliated with the institution are still employed and those that are not, no longer have permissions/access. Note: for larger institutions, an API gateway will automatically perform this analysis and identify discrepancies for further review. API User Experiences: Henry I am able to configure and assign different roles and permissions to users within my institution. I can configure my dashboard and prioritize my worklist to view tasks I can view and track metrics on I am able to customize s, requiring my attention. task completion. alerts and reminders. Henry Henry Henry Henry I have an intuitive dashboard interface that allows me to know where to begin when taking action on a task. Henry I can assign tasks to other users and attach notes to further explain my request. I am able to pay for multiple registrations at a time and receive a notification that my filing was successfully submitted. The system performs a completeness check and notifies me of any missing information before allowing me to submit filings. Henry I can grant a 3rd party access to my institution records and grant them permissions to complete activities on behalf of my institution. Henry I can utilize a 3rd party to assist me with all steps of the registration process. 102

105 #34 Workload Management for an Institution NMLS 2.0 Capabilities: NMLS 1.0 Pain Points: Performance metrics are often manually calculated by users. No way to assign and distribute work across institution users. Ability to assign tasks to individuals/groups Ability to easily toggle between one entity and another for which the user has an admin or organization role. Ability to customize the view of the dashboard by task, industry, institution, etc. Ability to modify the number of records that appear on the screen at one time Ability to search data within the system on specific screens and potentially with general search (including notes fields is nice to have) Ability to auto-assign certain tasks by task type. Ability to prioritize and assign workload items. Ability to set due dates for tasks. Ability to send multiple notifications to different parties when actions are taken notifications will be logged in audit trail. Ability to provide reminders for scheduled activities or other important dates. Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to initiate tasks based on user actions, another user's actions (who create a task for you), or system generated activities. Ability to allow a trusted third party to prepare, but not submit filings and/or attest on behalf of another person/entity. Ability to have a single login/profile, with access and association to multiple entities. And the ability to identify and change what entity you are working on currently and all entities that you have access to in the system. 103

106 NMLS 2.0 Journey Map Engagement Journey Map 34 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Journey #34 - Workload Management: When Jim provides Ted (3rd party user) the task, does Ted receive an or some kind of notification? Or does Ted only know of the new task when he logs into the system and accesses the company account? Ted should receive some type of notification so that he is aware that a task is coming the he needs to take action on from that client. Yes, in addition to an item being placed on the dashboard, a notification will also be sent to the relevant party. Flagged for Future Response Industry This is late, but wanted to respond anyhow on a few. #34 -What determines a company to be 'larger' for the API to automatically perform the analysis and identifying discrepancies? - Can only the AA for the company assign tasks or can any OU or 'designated OU by the AA' have the ability to do the task assignments? We have not defined larger entitles for API yet but will discuss this during that buildout. Roles and permissions have not been set. Would a role, exclusive to an AA, that allows the AA to designate an OU the ability to grant permissions be desirable? Would you need parameters around this? It seems simple to keep it clean and only allow AAs to assign roles and permissions given potential complexity but can explore this. Industry Step 1 1. How are licensees notified of tasks? a.do you need to be logged in & viewing dashboard? b.if notifications are delivered by , are they standard language? c. Ability to customize and add free form text? 2.Currently, each account user/teammate in an institution can see all institution activity; will users be able to view all institution activity from their dashboard or only those registrations they have initiated or tasks they have been assigned? 3.Can only an Administrator assign or re-assign tasks? We are working through these details on workload management and will ask these questions during the requirements process. Stay tuned for the ability to provide input on these items. Industry Journey #34 - Workload Management: When Jim provides Ted (3rd party user) the task, does Ted receive an or some kind of notification? Or does Ted only know of the new task when he logs into the system and accesses the company account? Ted should receive some type of notification so that he is aware that a task is coming the he needs to take action on from that client. Yes, a notification is sent to a person as part of the creation and management of tasks. 104

107 #35 Workload Management for a Regulator Personas: Journey Map This journey highlights the user experiences associated with Regulator users (e.g., Account Administrators, Organization users, Sam Jessica etc. ) that manage their workload via their intuitive, configurable dashboard. In the scenario below, there has been a recent surge of activity for new Regulator Account Regulator Organization User company and individual filings, which causes Sam, a Regulator Account Administrator, to rely on his team (Fernando, Michelle, and Jessica) to help the Administrator (State) (State) (responsible for agency close out these open tasks (e.g., reviewing company, branch, and individual filings, placing action items, accessing regulatory actions, reviewing researching regulatory actions) CBCs and credit reports). The core components of the journey include: completing and prioritizing tasks, managing and customizing the dashboard, Michelle auto assignment to a group or team members of a group based on a rotation or current workload capacity, auto-assignment based on defined rules, Regulator Organization User manual assignment, re-assignment by the assignee, re-assignment by the manager (e.g. for vacation or workload reassignment), dual assignments (State) (parallel review), and secondary review tasks. Fernando Regulator Organization User (State) Background: Human activity System activity Version 2, Delivered 4/12/17 BULK Option to perform action in bulk Operational Metrics Workload Balance Configuration Settings Dual Assignment Task Re-assignment Preceding Journey(s) Subsequent Journey(s) N/A N/A Sam, a Regulator Account Administrator, logs into the system to review his dashboard to get a sense of some of the operational metrics for his agency. On his dashboard, he reviews metrics such as the number of filings currently being reviewed by each of his staff and the average cycle time per review. User Experiences: Upon further review of the agency's operational metrics, Sam notices a disparity in the workload balance amongst his staff and decides to ease the load of one of his organizational users, Fernando. Sam reassigns some of Fernando's tasks to Jessica, by filtering on the tasks that have not been worked and reassigning several to Jessica. BULK Jessica receives a notification that additional tasks have been added to her worklist and require her attention. Note: task notifications are configurable by the user. Sam navigates to the State configuration page to configure the assignment (e.g., by name, license type, entity type) of flagged filings to go to Fernando, who has the most experience on the team. Sam also configures the system to prioritize any tasks on his dashboard that pertain to revoked licenses or business plan review. Note: Regulators have the ability to follow a task that has not been assigned to them. Fernando receives a few new items that have been added to his worklist based on configuration settings established by Sam. He begins to work each task, which require additional research as flags have been placed on these filings. For one complex task, he manually assigns the same task to Jessica so that they can perform their review in parallel (e.g., dual assignment) and collaborate to close the task. Sam receives a call from Michelle that she will be out of the office for two weeks starting tomorrow. Sam decides to re-assign her tasks to someone else while she is gone. Sam navigates to his dashboard and searches for Michelle to view her worklist. He re-assigns her tasks that have not been completed to a group of team members. The system assigns the tasks to each team member based on their current workload capacity. I am able to configure and assign different roles and permissions to users within my company. I can configure my dashboard and prioritize my worklist to view tasks requiring my attention. I can view and track metrics on task completion. Sam Sam Sam Sam I am able to customize s, alerts and reminders. Sam Jessica Fernando I have an intuitive interface and allows me to know where to start to take action on a task. Sam I can assign tasks to other users and attach notes to further explain my request. Fernando I can initiate tasks for users to provide me with information and documents, and they can respond within the system. Sam I can configure the system to send notifications to certain user groups within NMLS. 105

108 #35 Workload Management for a Regulator NMLS 1.0 Pain Points: No way to prioritize items on the worklist (e.g., renewal states first). The worklist has too many clicks required to view details of a work item, create license items, update license status, etc. Unable to share the work list with other departments. Confusion between work item and review item. Completing and archiving worklists causes performance issues and development limitations. Lack of assignment options: system currently limited to assigning worklist based on entity type (Company branch individual) and event type (license request, amendment, financial statement). Agencies have created workarounds by temporarily archiving items if its on hold, just to get it off their main worklist. Lack of granularity on work items (for example, individual work items are not split up by MU4 vs. MU2). NMLS 2.0 Capabilities: Ability to assign tasks to individuals/groups Ability to easily toggle between one entity and another for which the user has an admin or organization role. Ability to customize the view of the dashboard by task, industry, company, other Ability to modify the number of records that appear on the screen at one time Ability to search data within the system on specific screens and potentially with general search (including notes fields is nice to have) Ability to auto-assign certain tasks by state, work item type. Ability to prioritize and assign workload items. Ability to set due dates for tasks. Ability to send multiple notifications to different parties when actions are taken notifications will be logged in audit trail. Ability to provide reminders for scheduled activities or other important dates. Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to initiate tasks based on user actions, another user's actions (who create a task for you), or system generated activities. Ability to assign tasks to individuals/groups. 106

109 NMLS 2.0 Journey Map Engagement Journey Map 35 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Regulators need the ability to manage assigned tasks and clear them from the dashboard after addressing them, setting license items, etc., but want to use the task as a follow-up while waiting on company response. We cannot mark the item Completed necessarily if it includes multiple review items and unaddressed license items to company. Currently, there is no other status to put a pending task in (other than complete or incomplete. The task (work item has become a way to house notes, follow-up, etc., but depending on the complexity of the task, the work item may need to stick around in an incomplete status for a while, so we need a way to keep it segregated from other incomplete tasks that the regulator user has not yet initially addressed (prioritization. Perhaps multiple work item statuses on each work item would help, if the dashboard allows user to filter work items by status. Currently, can only filter by assigned/unassigned and complete/incomplete. Noted. Flagged for Future Response Regulator I agree. We use complete/incomplete & archive Noted. differently to track outstanding requests that have been reviewed but require follow-up. It works well for us, but makes our numbers look badly in data analytics reports. 107

110 #37 - Pre-Licensure Requirements (Control Person) Personas: Ryan Company Control Person (Direct Owner) Sally Company Control Person (Branch Manager) Journey Map Company Organization User (State) Background: Ryan and Sally indicated they are Control Persons at the end of the Account Creation journey, and now wish to complete all of the pre-licensure requirements. A step-by-step guided process begins which walks them through the process of entering the information / uploading the documents that are required for their filings. In addition,, the Company Organization User, guides Ryan and Sally through the process of completing their professional standards requirements. Note: Some states require control persons to fulfill additional requirements, such as obtaining an individual license or completing education credits. In these instances, control persons would also go through journey #3 - State License Filing Submission for a Licensee and / or journey #1 - Pre-Licensure Requirements (Licensee). Human activity System activity Version 2, Delivered 3/15/17 BULK Option to perform action in bulk Core Data Entry/Document Upload Criminal Background Check Credit Report Review Preceding Journey(s) Subsequent Journey(s) #15 - Account Creation (for State-Licensed Companies) #2 - State License Filing Submission for Company/Branch Ryan and Sally indicated they are Control Persons at the end of the Account Creation journey. A step-bystep guided process walks them through the process of entering core data and uploading commonly required documents. User Experiences: Ryan and Sally enter all core data that will automatically be prepopulated into state filings later (e.g. work history), and upload commonly required documents that will be needed (e.g. personal identification). The system notifies Ryan and Sally that they need to complete a criminal background check (CBC). Ryan and Sally click on the CBC section of the professional standards page to schedule fingerprinting via the NMLS approved vendor. They also have the option to use existing fingerprints, if still valid (i.e., less than state maximum # of days/years). The CBC will be paid for by, who is configured as the default payer for all of his company users' activities in NMLS. Ryan and Sally get fingerprinted, if necessary. Their full CBC request will be submitted at the time of filing submission. The CBC will then be stored as part of Ryan and Sally's NMLS record, and is only viewable by users with the right permissions. The system also notifies Ryan and Sally that they need to authorize a credit report. Ryan and Sally click on the credit report section of the professional standards page to authorize the credit report, which will not be pulled until filing submission. The credit reports will be paid for by, who is configured as the default payer for all of his company users' activities in NMLS. Ryan and Sally view their record in NMLS to confirm all of the professional standards requirements have been satisfied and all core data / documents are as complete and accurate as possible in order to facilitate a faster filing process in the next journey. The easy-to-follow guided process walks me through all of the steps that I need to complete as a Control Person. The guided process makes it easy to select the license my company/ branch is applying for and lays out all of the requirements in a single place. I am able to view detailed instructions on how to complete all of the professional standards requirements. If I have a question while I am completing tasks, I can access specific help resources right on the screen I am working on. Ryan Sally Ryan Sally Ryan Sally Ryan Sally Ryan Sally My professional standards requirements become part of my NMLS record, and can be used across multiple filings. My NMLS record displays the status of all of the prelicensure professional standards requirements. I can configure the system to be the default payer for all of my company users' activities in NMLS. The system pre-populates my filing by pulling information stored in my record. Ryan Sally Ryan Sally Ryan Sally I am able to use my mobile device to complete aspects of the pre-licensure requirements. 108

111 #37 - Pre-Licensure Requirements (Control Person) NMLS 1.0 Pain Points: Users are unsure where to start in the licensing process. Varying state requirements (which are external to the NMLS system) create confusion during the filing submission process. Difficulty locating help resources on the Resource Center. Users have difficulty determining which license they should be applying for. Profile information is not validated against third party data sources. addresses are not validated and sometimes users will enter an incorrect address. The application workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process. Criminal Background Check process does not include fingerprint scheduling. Payments collected through NMLS are non refundable. There is no ability to auto-fill filings which leads to entering data that is already in the system. Users are able to complete certain actions that their company may not want them to complete. NMLS 2.0 Capabilities: Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to attach personal details to personal profile, such that changing companies does not invalidate certain personal details (e.g. valid fingerprints) Ability to capture multiple addresses (work and personal) in a user profile. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, EIN, addresses, etc.). Ability to attach professional standards requirements to a user's record. Ability to see progress while completing the pre-licensure requirements (e.g., visually represent where the user is in the overall workflow). Ability to include state requirements and allow state agencies to edit these requirements. Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to re-use background and credit checks that are stored in a user's record. Ability to suggest properly formatted addresses upon received error (any bulk uploads / API integrations). Ability to validate that addresses are consistent across filings. Ability to indicate what fields are required prior to entry and after form submission (if required fields were omitted). Ability to check submitted forms for completeness against requirements and provide immediate user feedback on gaps/errors/omissions. Ability to have role-based security access. Ability for users to assign roles and permissions. Ability for companies to control what steps individuals have access to. Ability to perform file validations on uploaded files. Ability to tag documents with metadata in the document upload section based on workflow and context. Ability to upload multiple files at one time. Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. 109

112 NMLS 2.0 Journey Map Engagement Journey Map 37 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry In our organization, most control persons do not have a license. In this map all filings are done by (the company Organization User) through the MU1 and then then Control Person attests to all updates. In 2.0 will a control person be able to submit a filing when they do not have a license or license application? In 1.0 would update the Control Person's information, when required through the MU1 and then requests attestation by the Control person. The Journey map mentions that is the default payer for all of company users' activities in the NMLS. This is fine for a Control person, but we do not pay for our employee licenses and renewals. Will there be an option for to either pay or push it back to the employee to pay? Yes. A control person will be able to attest and submit a filing if they do not have a license or license application. There will also be options for who pays (the company or the employee). Flagged for Future Response Industry Industry Industry Most large corporations do not have Control Persons as MLO s, however, if they do, the company user will complete all steps other than the specific education, testing, fingerprinting, etc. requirements. Will there be an opportunity for the company to complete the other steps? Steps 2, 3, 4: As with Journey #15, can request these items for Ryan and Sally? The core data, criminal check, and credit may all be entered or selected by the Account Administrator so that the Control Person only has to complete the actual fingerprints and attestation and not the populating of data in NMLS. Can upload documents or set up the account on Ryan/Sally behalf? can there be more than one default payer other than? We have multiple individuals in our licensing dept. that pay for not only control persons licensing (if applicable) but for all individual licensing. Having this is essential for us. Can the filing be submitted w/o a license, so just to run the CBC and Credit checks? As most of our control persons do not hold MLO licensing. Yes. As in the map attempts to show, will have accesses to the record and will be able to complete the necessary steps (less T&E, etc.) on behalf of the control person. Yes, the company organized user will be able to populate the information and "set-up" the requirements so that the control person will only need to attest to and complete the actual requirement. Yes, the company organization user will be able to set the account and complete other tasks in preparation for the control person to attest, get fingerprinted, and authorize the credit check. There will also be option for the company or the employee to pay. The filing can also be completed without the requirement for license. 110

113 NMLS 2.0 Journey Map Engagement Journey Map 37 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Will the CBC be handled in the same manner as it currently on the NMLS? There was not a great amount of detail on this point. Mobile device use what tasks will the individual be able to complete on their mobile device? It is our understanding that the proposed changes would require control persons to complete relevant CBC/fingerprinting requirements before an application is submitted. We agree that under the current process, it is not necessarily obvious that additional action will be required once a Form MU2 is submitted (because control persons have the ability to attest to an MU1 and complete fingerprinting requirements later), and that failure to complete these requirements quickly may cause applications to sit in pending status for extended period of time. However, would corporate applicants be barred from submitting license applications until all control persons have completed the pre-requisite criminal background check? Given that control persons are not always immediately receptive to completing items like fingerprinting, this could cause a problem for the corporate license applicant if it is under pressure to get an application on file with a regulator quickly. On the CBC process, we don't anticipate the need to change major portions of this - but if you have ideas let us know. State regulators have requested that only complete applications be allowed to submitted and this potentially would include FP on file to immediately process the CBC. This is why the FP capture was moved up earlier in the process to allow a more complete application to state regulators. On mobile - we haven't defined it but would most likely start out with focused abilities (attest and pay and submit), edit some key information, etc. We will definite this further in a future sprint and will provide ideas for folks to react to when we have this ready. Flagged for Future Response Regulator A clarifying question for Map #37 Step 3 - It talks about using archived fingerprints and the 3 year rule. One of the previous maps regarding MLOs talked about RAP Back being incorporated into NMLS 2.0. This would be for control people too, right? If so, with RAP Back, would the prints need to be re-run or would the existing results just be opened to the new state to view and then that new state would receive any new activity on the CBC results? In other words, would archived prints and the three year rule still be applicable with RAP Back? Great questions! Right now, CSBS has authorization for RAP back on MLOs and is working on Control Person authorization. We are working with the FBI on the "currency" of fingerprints as we pursue RAP back. The FBI currently requires us to ensure the prints submitted for a CBC request be "current" in order to capture any changes from scars or other. Stay tuned. 111

114 NMLS 2.0 Journey Map Engagement Journey Map 37 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Flagged for Future Response Regulator Regulator Will there be an approval in place where the Company can review and possibly edit the requests for payment by the individual. For example, if the individual selects five licenses that he or she is not qualified for according to the company, can the company edit the cart and send the cart back saying that they will only pay for 2 licenses out of the 5. If there is not a review process in place, individuals will want the company to buy each and every state license. There needs to be a regulatory process. I would like if they were able to schedule and complete their fingerprints prior to submitting the application. In my state, they have 60 days to complete certain items and I know that we've had issues with people submitting an application and not going to get their fingerprints done in the allotted time-frame. That creates more work for us (having to keep track of the individuals and going in to the NMLS to see if the results have come in) and also makes the individual pay twice if their application is abandoned and they have to reapply. Thanks. We will add this to the workflow discussion on requirements. We're envisioning all requirements would be required to be completed prior to the submission of the application. 112

115 #38 - Company / Branch Setup Personas: Journey Map Company Organization User (State) Jim Company Account Administrator (State) Background: After creating accounts for himself and his employees, Jim, a Company Account Administrator, wishes to create his company and branch records. Jim has assigned permission to, a Company Organization User, to establish and maintain these records. is responsible for all of the initial core data entry and document uploads that are required to apply for licenses in each applicable state. A step-by-step guided process walks through the process of selecting the licenses he would like to eventually apply for, understanding what the requirements are, and entering the information / uploading the documents that are required. Human activity System activity Version 4, Delivered 4/14/17 BULK Option to perform action in bulk Preceding Journey(s) #15 - Account Creation (for State-Licensed Companies) Core Data Entry / Document Upload Review License Selection Subsequent Journey(s) #2 - State License Filing Submission for Company/Branch From his dashboard, clicks a button to create company and branch records. User Experiences: is guided through all of the core data entry that is required for the company, such as business activities, identifying information, other trade names, disclosure questions, books and records, bank accounts, affiliations, and org structure. This data will be automatically populated into filings in the future. starts entering all of the branch information. He adds a branch, enters items such as address and designated branch manager(s), and then adds additional branches. If a branch manager has not been assigned, he can leave it blank and enter it at the time of filing. This data will be automatically populated into filings in the future. BULK uploads commonly required documents into his company's document repository (e.g., business plan, financial statements, org. chart, permissible investments, etc.). If executes an electronic surety bond, he will have the option to include it with the filing later, but also has the option to upload any non-electronic surety bonds. Commonly required documents will automatically be attached to filings in the future. views the company and branch records in NMLS to confirm all of the core data / documents are as complete and accurate as possible in order to facilitate a faster filing process in the next journey. The easy-to-follow guided process walks me through all of the steps required to complete my company and branch records. The guided process makes it easy to select the license my company/branch is applying for and lays out all of the requirements in a single place. BULK I am able to quickly and easily navigate throughout the different sections of the records and the on-screen status bar keeps track of my progress.? At this point, is prompted to answer a series of questions which helps determine the specific licenses he would like to apply for. He is provided with a filtered down list based on the business activities he selected at account creation. This process can be completed now in order to gather all required information and documents ahead of time to make filing easier, or at the beginning of the filing process. The user interface for entering data is very intuitive and well organized. selects the state(s) where he would like to apply for company / branch licenses. selects the appropriate license(s) and is provided with a full list of the requirements that are needed for filing. gathers the required information / documents, and is now ready to begin his company and branch filings. If I have a question while I am completing the records, I can access specific help resources right on the screen I am working on. The system performs a completeness check and notifies me of any missing information before allowing me to finish. The system pre-populates filings by pulling information stored in the company and branch records. I am able to add or delete documents from my company's document repository. I can easily upload all of the documents that my company needs at once, and can label and organize them for easy retrieval later. I am able to view on-screen help instructions to ensure I upload the correct documents. 113

116 #38 - Company / Branch Setup NMLS 1.0 Pain Points: Company users are unsure where to start in the licensing process. Varying state requirements (which are external to the NMLS system) create confusion during the filing submission process. Difficulty locating help resources on the Resource Center. The application workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process. Users do not have the ability to place notes on a filing. (e.g., a note indicating what a filing was for so the fillings can be identified later on.) Lack of settings to enforce specific document uploads based on license type. Agencies have difficulty managing the volume of uploads and identifying changes to documents. States often require documentation that is not on the checklists. Unable to upload certain documentation upfront to provide information the state wants (e.g., work authorization). The upload functionality is limited: unable to provide more than one document at once, size limit constraints, document choices are limited, and wet signature required for some states. Lack of data uniformity across states (e.g., certain states care about "St." vs. "Street.") Users do not receive confirmation that they have submitted all required information. When addressing disclosure questions, if a user answers "Yes", the user does not know what documentation to upload. NMLS 2.0 Capabilities: Ability to have role-based security access. Ability for users to assign roles and permissions. Ability for companies to control what steps individuals have access to. Ability to assign tasks to individuals/groups. Ability to leave and come back to a filing and resume in the same location (i.e., save and continue). Ability to include state requirements and allow state agencies to edit these requirements. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to bulk upload data (file upload) or bulk complete actions (multi-record select) in order to complete actions on multiple records at once. Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to see progress while completing the filing (e.g., visually represent with a status bar where the user is in the overall filing workflow). Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to upload documents for review by the selected state licensing authorities. Ability to upload multiple files at one time. Ability to tag documents with metadata in the document upload section based on workflow and context. 114

117 NMLS 2.0 Journey Map Engagement Journey Map 38 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Step 4: Are the commonly required documents going to be reviewed and agreed upon by the states so that the company knows exactly what to upload? Step 6: Is the system going to determine what licenses a company needs based on what activity the company enters? This seems like it could be a potential risk of either missing licenses or requiring licenses that may not be required due to some exemptions. Yes, uniformity is the goal. Flagged for Future Response Regulator Will it be possible for states to block applications for branch licenses on de novo applications for company licenses? This should be a setting that states will have the option to set. 115

118 #39 - Account Creation (Regulator) Personas: Journey Map Sam Regulator Account Administrator (State) Background: Fernando, a Regulator Organization User, was recently hired by a state agency to perform filing reviews. Fernando does not have an existing NMLS account, so his supervisor, Sam, a Regulator Account Administrator, creates an account for him. This journey walks through the steps of creating the account, assigning roles and permissions, and account setup. Fernando Regulator Organization User (State) Human activity System activity Version 2, Delivered 3/29/17 BULK Option to perform action in bulk Account Creation Preceding Journey(s) N/A Account Setup Next Steps Subsequent Journey(s) N/A From his dashboard, Sam clicks a button to create a new account. He enters basic identifying information about Fernando, such as his name, SSN, and address. Fernando's information is validated against external data sources and against rules to prevent duplication (e.g. duplicate addresses) BULK User Experiences: Sam also assigns Fernando to the role of Organization User, which gives specific permissions to Fernando such as the ability to perform certain tasks and access data. Sam confirms that the agency is the employer for Fernando. Fernando separately acquires a credential directly from NMLS s approved two-factor authentication vendor after his account is created. Fernando receives a login and password in his and logs into NMLS for the first time with his two-factor authentication credential. He changes his password, sets security questions for self-service password reset, and includes a personal address for account recovery. He is required to confirm his personal address. Fernando reviews and confirms the information entered by Sam before being allowed to continue, and completes his own personal profile information such as address, phone number, etc. He also approves the employer previously assigned by Sam. After completing the account set up, Fernando is taken to his dashboard and presented with options regarding what he would like to do next (e.g. complete assigned tasks, etc.). Sam I am able to view detailed and easy-to-use instructions on how to create an account. Sam A complete list of all the information I need to set up my account is included right on the screen. Sam I am able to establish accounts and set roles and permissions for my agency's users during the account creation process. Fernando I am automatically notified when my account is created in NMLS. Fernando I can change my password without having to call my Account Administrator. If I have a question while I am setting up an account, I can access specific help resources right on the screen I am working on. The system automatically validates the information that I enter, such as my SSN, address, etc. Fernando Fernando Fernando I receive a single login which gives me the ability to perform work for all departments I am affiliated with. 116

119 #39 - Account Creation (Regulator) NMLS 1.0 Pain Points: Difficulty locating help resources on the Resource Center. The account request process is currently done outside of the system through the call center. The system doesn't validate if a user already has an account, leading to the creation of duplicate accounts. Profile information is not validated against third party data sources. addresses are not validated and sometimes users will enter an incorrect address. Individuals without a SSN have challenges receiving an NMLS ID. Users have to maintain multiple logins and passwords to manage the various entities they are affiliated to. There is an insufficient level of granularity when it comes to existing permissions. Users often don't know what exactly they are granting access to when providing access to another user. Users are able to complete certain actions that their agency may not want them to complete. NMLS 2.0 Capabilities: Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to easily toggle between one entity and another for which the user has an admin or organization role. Ability to capture multiple addresses (work and personal) in a user profile. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, EIN, addresses, etc.). Ability to have a single login/profile, with access and association to multiple entities. Ability to suggest properly formatted addresses upon received error (any bulk uploads / API integrations). Ability to indicate what fields are required prior to entry and after form submission (if required fields were omitted). Ability to have role-based security access. Ability for users to assign roles and permissions. Ability for agencies to control what steps individuals have access to. Ability to notify users via . (e.g., NMLS login credentials). Ability to send multiple notifications to different parties when actions are taken (e.g. account is created). Ability to reset password without calling the Contact Service Center. 117

120 NMLS 2.0 Journey Map Engagement Journey Map 39 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator For Map #39, our agency has concerns about regulator users needing to enter a SS# like a licensee user would do. According to our HR Department, even the online state payroll system uses an employee's personnel ID #, not their SS# for identification purposes. SRR understands the concern and is exploring multiple options. Flagged for Future Response X For Map#39 - Object to use of SSN for registering regulatory staff. SSN should only be required for credit, tax or background check purposes. Regulator Is there any thought to an individual regulator starting the account creation and then the account administrator can search for them and associate them to the agency? The account creation (even for regulators includes SS#) which isn't typically something I, an account administrator but fellow employee, have available. Also, what happens if the new employee actually did have a previous NMLS account, but didn't remember he/she had an account. Will an error be generated when I try to create them new? The current plan is to have the agency administrator initiate the process for new regulatory users. The regulatory user would be responsible for data entry, verification and authentication. Regulatory users with prior NMLS accounts would work with their new employer (agency) to affiliate their account properly. Regulator At what point in this map would the account administrator place the new employee within the agency's organizational structure as established in Map 17? Step 2 speaks to assigning the user the role of Organizational User which gives specific permissions, but a Licensing Reviewer will have much different permissions than an Examiner (different Unit in the org structure) - I believe each is an organizational user, though. Multiple roles will be created for agency admins to choose from - including those aligned with licensing review or examinations. The roles would provide the basic permissions for those work types, but would allow the agency admin to manage permissions individually in order to tailor specific needs to individual users. Regulator Our agency has concerns about regulator users needing to enter a SS# like a licensee user would do. According to our HR Department, even the online state payroll system uses an employee's personnel ID #, not their SS# for identification purposes. We are looking at other data points to make entry of an SSN by regulatory users optional. It is highly likely that regulatory users will NOT be required to enter an SSN. 118

121 NMLS 2.0 Journey Map Engagement Journey Map 39 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Object to use of SSN for registering regulatory staff. SSN should only be required for credit, tax or background check purposes. We are looking at other data points to make entry of an SSN by regulatory users optional. It is highly likely that regulatory users will NOT be required to enter an SSN. Flagged for Future Response 119

122 #40 - Designated 3 rd Parties Personas: Journey Map Jim Company Account Administrator (State) Ryan Company Control Person (Direct Owner) Sally Company Control Person (Branch Manager) Mary Individual Licensee (State) Ted Designated 3 rd Party User Background: This journey highlights the user experiences of a new state-licensed company that has hired a Designated 3rd Party to help them manage the licensing process. As the company is small, has limited resources, and does not fully understand the state licensing requirements, they have decided to hire Ted's firm for assistance. Jim, the Company Account Administrator, has created his NMLS account as well as the company record. He then grants Ted access to the company record and grants him most of the permissions that a Company Organization User would normally have, with the exception of being able to attest and submit filings. Ted is responsible for managing the entire licensing process, including creating accounts, establishing records, ensuring company users complete their professional standards requirements, creating filings, and performing effective dated changes throughout the year. Ted also has several other clients, and he uses a single login to manage all of their licensing activities by toggling back and forth between the different entities he has access to. Human activity System activity Version 2, Delivered 4/12/17 BULK Option to perform action in bulk Granting Access & Permission Entity Selection Account Creation Pre-Licensure Requirements Company/ Branch Setup License Type Selection Company/Branch Filings Individual Filings Action Items Maintenance Preceding Journey(s) #15 - Account Creation by Company Account Administrator (for State-Licensed Companies) Policy Discussion: Should Designated Third Party users have the ability to create accounts on behalf of their clients? Should Designated Third Party Companies be validated? Subsequent Journey(s) N/A A new statelicensed company has hired a Designated 3rd Party to help them manage the licensing process. Jim, the Company Account Administrator, has created his NMLS account as well as the company record. Jim grants Ted, Ted logs into NMLS and the Designated is taken to his 3rd Party User, dashboard. Ted has access to the several other clients as company record well, and from this one and grants him centralized dashboard, most of the can toggle back and permissions that forth between all of the a Company entities that he works Organization on. He can also assign User would tasks, send notifications, normally have, and perform all tasks with the related to account exception of administration and being able to licensing. Ted selects attest and Jim's company from his submit filings. drop-down menu, and his screen makes it very clear which entity he is working in. User Experiences: Ted begins by creating a task for Jim to provide him with the information he needs to create accounts and filings for each of the company users, including Ryan, Sally, and Mary (e.g., names, SSN, addresses, etc.) Jim sends Ted a file in the system with the requested information. Ted creates accounts for each of the company users. See #15 - Account Creation (for state and federal entities) for more details on this process. Ted creates tasks for each company user to provide him with commonly required documents, and uploads them into each user's record. Ted schedules fingerprinting and authorizes credit checks for each user. See #1 - Pre-Licensure Requirements (Individual State Licensee) and #37 - Pre-Licensure Requirements (Control Person) for more details on this process. Ted then completes the company and branch record set up. Ted adds Ryan and Sally as control persons, and the system creates and sends them control person filings for attestation. See #38 - Company / Branch Setup for more details on this process. Ted is prompted to select which action he would like to complete next, and selects the option to file for licenses. Ted is prompted to answer a series of questions which helps determine the specific license he would like to file for, such as what type of business and activities he will be engaging in. He is also asked to select the state where he would like to file. At this point, Ted needs additional information from Jim regarding the license selection, and creates a task for Jim to provide the information. Jim responds back with the requested information. Ted selects the appropriate licenses and is provided with the requirements. Ted creates another task for Jim if he needs additional required information / documents. Ted initiates the company and branch filings, and is guided through the filing process step-by-step. See #2 - State License Filing Submission for a Company/Branch for more details on this process. Ted completes the filings and sends them to Jim. Jim reviews the filings, provides his attestation, pays the invoice, and submits. After submitting the company and branch filings, Ted is prompted to submit filings for individual licensees. Ted initiates the filings with a bulk upload template, and is guided through the filing process stepby-step. See #3 - State License Filing Submission for an Individual Licensee for more details on this process. BULK Ted completes the filings and sends them to each individual. The individuals review the filings and provide their attestations. Once attestations are complete, Ted creates a task for Jim to pay a single invoice for all filings and submit. Ted is notified if the regulator places any action items on the filings, and works with Jim and the individuals to resolve them. Ted is also notified when the filings are approved. I can manage all of my clients' activities with a single NMLS login. BULK I can grant a 3rd party access to my company records and grant them permissions to complete activities on behalf of my company. BULK I am able to quickly toggle between entities that have granted me permission to act on their behalf in the system. I can utilize a 3rd party to assist me with all steps of the licensing process. If I have a question while I am completing tasks, I can access specific help resources right on the screen I am working on. Ted Jim Ted Jim Ted Ted? I can initiate tasks for users to provide me with information and documents, and they can respond within the system. Ryan Sally Mary The 3rd party user makes sure I complete all of my professional standards requirements. Throughout the year, Ted works closely with Jim and his company users to process any effective dated changes. He also makes sure individual licensees complete professional standards requirements such as continuing education. At the end of the year, Ted manages all renewals for the company during renewal season. Ted I am able to complete all steps of the application filing process within NMLS, including communicating with other users and uploading/ submitting all documents. Ryan Sally Mary I receive an notification that a company has created a filing on my behalf that requires my attestation. Ryan Sally Mary I can attest to my filing on my mobile device, and can get to the attestation page from a link found in the I receive. Ted I am able to track the status of my license filing during regulator review and view onscreen definitions for each license status within NMLS. Ted I can initiate filings in bulk for individual licensees. Ted I receive notifications whenever an action is initiated that requires action on behalf of one of my client's users. 120

123 #40 - Designated 3 rd Parties NMLS 1.0 Pain Points: Need to maintain separate accounts for each entity and need to log in and out of these accounts to complete required tasks. Unable to communicate with other users in the system. Company users are unsure of where to start in the licensing process. Varying state checklist requirements (which are external to the NMLS system) create confusion during the filing process. Difficulty locating help resources on the Resource Center. The application workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process. Users do not have the ability to place notes on a filing. (e.g., a note indicating what a filing was for so the fillings can be identified later on.) Applicants are unsure of the status of their application after submitting. NMLS 2.0 Capabilities: Ability for companies to control what steps individuals have access to. Ability to assign tasks to individuals/groups. Mobile capability for core licensing workflow functionality (smartphone, tablet). Ability to notify users via . Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to have a single login/profile, with access and association to multiple entities. And the ability to identify and change what entity you are working on currently and all entities that you have access to in the system. Ability to customize the view of the dashboard by task, industry, company, other. Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to upload documents for review by the selected state licensing authorities. Ability to upload multiple files at one time. Ability to tag documents with metadata in the document upload section based on workflow and context. Ability to see progress while completing the filing (e.g., visually represent with a status bar where the user is in the overall filing workflow). Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to leave and come back to a filing and resume in the same location (i.e., save and continue). Ability to include state requirements and allow state agencies to edit these requirements. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). Ability to bulk upload data (file upload) or bulk complete actions (multi-record select) in order to complete actions on multiple records at once. Ability to make multiple payments in one invoice similar to a shopping cart concept. Ability to allow a trusted third party to prepare, but not submit filings and/or attest on behalf of another person/ entity. Ability to have insight into state regulator review progress. Ability to send multiple notifications to different parties when actions are taken. 121

124 NMLS 2.0 Journey Map Engagement Journey Map 40 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Industry #40 In step #16 will Jim be notified of approved licenses as well as Ted? so Jim can update any internal systems to activate the individual to do business in that/those states Journey #40 - Designated 3rd Parties: Jim grants company access to Ted. When and how does Ted create his account for Jim to then access? As a third party user, I love this! The one log-in, as well as the communication abilities with the clients and regulators through the system will be much more time efficient and practical. We anticipate that users will be alerted and directed to resolving issues well in advance of rd. Parties 3rd par period. The Designated 3rd Party will go into 2.0 and set-up their own account with an account administrator. Once the account is established, the 3rd party will be able to make an association with another company for the management and completion of tasks. Flagged for Future Response Regulator Step 16: Just want to make sure that the functionality exists for the regulator to communicate confidentially with an individual (either via a confidential license item or some other means of communication through the NMLS). This would be used to reference CBC, credit, or other confidential information that cannot be divulged to a third party. Yes. There will be the concept of a private communication that is not visible to other users. 122

125 #41 - License Termination Personas: Mary Individual Licensee (State) Sam Regulator Account Administrator (State) Journey Map Bob Sole Proprietor Background: This journey captures the experiences involved with the license termination process in 2.0. There are various. reasons that a license could be terminated by a state regulator, including: failing to renew, a regulator rejecting a renewal for flagged items, regulatory actions against a company or individual, criminal background check findings, and other incidents involving a company or individual. In this journey, various company and individual licenses are terminated by Sam, Regulator Account Administrator (State), for each of these reasons. Sam employs one of the following methods to terminate each license: automated termination, manual termination, or bulk termination. Human activity System activity Version 2, Delivered 4/10/17 BULK Option to perform action in bulk Automated Termination Bulk Termination Manual Termination of Company/Branch Licenses with Regulatory Action Preceding Journey(s) #7 - State Regulator Review of Company/Branch Filing #8 - State Regulator Review of Individual Licensee Filing #9 - State Regulator Review of Company/Branch Renewal #10 - State Regulator Review of Licensee Renewal Subsequent Journey(s) #2 - State License Filing Submission for Company/Branch #3 - State License Filing Submission for an Individual Licensee Renewal season is approaching, and Sam wants to configure automated termination for non-perpetual licensees that fail to renew. Sam logs into his regulator portal. User Experiences: Sam indicates that his agency participates in late renewal. In this scenario, licensees have until the last day in February to submit their renewal filings. The system will terminate licenses where a renewal was not filed on 3/1 with an effective date of the last day of February. States that do not participate in late renewal would terminate licenses on 1/1 with an effective date of 12/31. During renewal season, Sam receives a number of filings where the system flagged certain items for additional review based on the rules/thresholds that Sam previously configured in the regulator portal. One of these filings belongs to Mary, an Individual Licensee, who was convicted of a crime during the year. Sam reviews Mary's filing in more detail and determines she is no longer fit to do business in his state. Sam reviews the other filings that were flagged for various reasons, and after undergoing due process, determines that a total of 10 of these licenses should be terminated, including Mary's. Sam decides to use the bulk termination functionality within NMLS to terminate these 10 licenses, and includes a reason, along with any next steps (e.g. cease doing business, file an appeal, etc.). BULK The licensees receive notifications that their licenses have been terminated for various reasons and are presented with next steps. A few months after renewal season, Sam is notified of criminal activity on Bob's record through the Rap Back functionality. Bob is a sole proprietor and possesses both a company and individual license. Sam conducts an investigation and after undergoing due process, determines that it is necessary to terminate each of Bob's licenses. Sam searches for Bob's company in the search bar on his dashboard and selects the company from the drop-down. Sam terminates both Bob's company and individual licenses, adds any regulatory actions to Bob's record (if applicable), and enters the reason and next steps. See #22 - Posting Regulatory Actions for more detail on regulatory actions. By terminating the company license, the system will also terminate any underlying branch licenses, and place any individual licenses for employees into an unaffiliated status. Sam Sam I am able to configure automated termination for licensees that fail to renew by my state's deadline. I am notified when one of my licensees has a license terminated in a different state. Sam Sam The system helps me determine which licenses I need to terminate by flagging items for additional review based on the rules/ thresholds I configured. I can easily search and find the license(s) that I wish to terminate. Sam Sam I can utilize the bulk termination functionality within NMLS to terminate more than one license at a time. I am notified throughout the year when one of my licensees has criminal activity on their record through the Rap Back functionality. Mary Oliver Sam Bob The system provides me with the reason my license was terminated as well as any next steps. When I terminate a license, the system updates the licensee's license history. Bob receives a notification that his licenses have been terminated along with the reason. He is presented with next steps, which could include updating his disclosure questions. 123

126 #41 - License Termination NMLS 1.0 Pain Points: Trickle-down impacts are unclear if sponsoring company license is terminated, should have an automatic impact on sponsored MLOs and corresponding branch license statuses. The various license statuses related to failure to renew are very confusing and not intuitive. The process for terminating licenses is clunky (e.g. upload a list of licenses already in a terminated status that are not actually terminated in order to execute the termination). The worklist is very confusing, does not allow a user to prioritize items, and contains items that don't even require action. Users are unable to customize the view of a worklist. The worklist doesn't provide an accurate picture of a user's true workload. No ability to mark items as resolved or clear them from the worklist. There is no functionality for automated terminations. NMLS 2.0 Capabilities: Ability to track all actions, activities, and changes with an audit trail (e.g., who, what, when, why). Ability to attach regulator/reviewer contact information to license items/communications. Ability to view/generate a full or object-level audit trail (e.g. list of changes made to a company license record). Ability to identify certain individuals based on prior "bad actor" activity (i.e. a blacklist -- which exists offline today at the state level). Ability to set regulator fees and other configurable license requirement and workflow settings. Workflow will require all changes to go through SRR review prior to going into effect. Ability to notify State Regulators when a LO has been revoked in any state. Ability to trigger reviews based on defined and configurable business rules (e.g., flagged items). Ability to put an administrative hold on licensees who have flagged with possible issues. Ability to configure by states when certain items need to be reviewed during renewals such as credit checks, CBC, and finger prints needing to be renewed. Ability to interface NMLS with external systems such as Fieldprint, FBI, Transunion. Ability to automatically update object record data when actions are taken on that object (e.g. update employment record when hired / terminated / transferred). Ability to assist users with a step in the process based on the stage of the process and also on a page (i.e., contextaware help guides and videos to assist people with the process) help resources should be right on the page. Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to function as a real-time system where changes are reflected throughout the application immediately. Ability to send multiple notifications to different parties when actions are taken (e.g. license is terminated by regulator, then individual, company, and other regulators could all be notified). Notifications will be logged in audit trail. Ability to see other State Regulator notes on credit report reviews, any document or aspect of a record (financials, MCR, etc.), but need to think through the privacy concerns. Ability for regulator to search for a company owner and identify where there may be common ownership with other entities. Ability to initiate tasks based on user actions, another user's actions (who create a task for you), or system generated activities. Ability to bulk upload data (file upload) or bulk complete actions (multi-record select) in order to complete actions on multiple records at once (e.g., license termination). 124

127 NMLS 2.0 Journey Map Engagement Journey Map 41 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Journey #41 - License Termination: Do state regulators have the ability to send notifications to licensees in advance of a termination, such as to provide additional information regarding the issue? Or will licensees all of a sudden be terminated with no warning, and then possibly be conducting business without a license? We anticipate that users will be alerted and directed to resolving issues well in advance of termination terminal period. Flagged for Future Response Industry #41 Will the 'Do Not Renew' option for licensees be available still and automatically terminate 1/1 effective 12/31? If automated termination is done 3/1 for late renewal, is the licensee's status put into some sort of approved-inactive status or something after so they know not to do business until approved for the late renewal or ultimately terminated 3/1? Concern on the notification to individuals. In the past, Regulators will reach out to our individual licensees to give them an option to w/d or do not renew before they terminate. will that option be open still? or will the Regulator just have to communicate outside the NMLS w/ the individual instead? We anticipate that users will be alerted and directed to resolving issues well in advance of termination terminal period. 125

128 NMLS 2.0 Journey Map Engagement Journey Map 41 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Map #41: Several of the 2.0 capabilities listed may touch on this, but our agency would like to be able to view the credit and criminal background data of certain licensees in a terminated status. If a terminated licensee has a pending renewal we would like to have the same access to their account we had prior to them going into a terminated status. This is mainly an issue during MLO renewal. Since we review both criminal & credit at renewal and don't use auto renewal or perpetual for MLOs, there is always a group of pending renewals who as of January 1st aren't approved or rejected yet. Those really should stay in a terminated status after January 1st until we reach a renewal decision. However, we have to keep many in an approvedinactive status after January 1st so we are able to properly review the merits of their renewal application. In addition, the license status itself creates confusion for industry. We are consolidating/rationalizing license and renewal statuses to make it clear to end users if they can conduct business or not. We will institute other methods for a status marker of "where they are in the process" which will help with your last comment. For access to CBC and Credit - we currently end access for security reasons and have a manual process for access. Keep in mind that both the FBI and TU require the use of current documentation when making decisions per the agreements. We should explore the business case and the parameters set by these providers. Flagged for Future Response Industry Journey #41 - License Termination: Do state regulators have the ability to send notifications to licensees in advance of a termination, such as to provide additional information regarding the issue? Or will licensees all of a sudden be terminated with no warning, and then possibly be conducting business without a license? Regulators have the ability to send a notice of pending termination. However, 2.0 may also automatically terminate the license i.e. when the renewal deadline has passed. 126

129 NMLS 2.0 Journey Map Engagement Journey Map 41 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator Several of the 2.0 capabilities listed may touch on this, but our agency would like to be able to view the credit and criminal background data of certain licensees in a terminated status. If a terminated licensee has a pending renewal we would like to have the same access to their account we had prior to them going into a terminated status. This is mainly an issue during MLO renewal. Since we review both criminal & credit at renewal and don't use auto renewal or perpetual for MLOs, there is always a group of pending renewals who as of January 1st aren't approved or rejected yet. Those really should stay in a terminated status after January 1st until we reach a renewal decision. However, we have to keep many in an approvedinactive status after January 1st so we are able to properly review the merits of their renewal application. In addition, the license status itself creates confusion for industry. We are consolidating/rationalizing license and renewal statuses to make it clear to end users if they can conduct business or not. We will institute other methods for a status marker of "where they are in the process" which will help with your last comment. For access to CBC and Credit - we currently end access for security reasons and have a manual process for access. Keep in mind that both the FBI and TU require the use of current documentation when making decisions per the agreements. We should explore the business case and the parameters set by these providers. Flagged for Future Response 127

130 #43 - Account Creation (Individual Licensee) Personas: Mary Individual Licensee (State) Background: Mary is a recent college grad who is currently looking for a job, and is interested in obtaining a license in her state. Mary searches for how to apply for a license, and is directed to the NMLS website to find the instructions on how to request a new account. After creating and setting up her account, Mary will be able to begin all of the necessary licensing activities, such as selecting the license she would like to apply for, understanding what the pre-licensure requirements are, and entering the information / uploading the documents that are required and will be used later in her filing. Journey Map Human activity System activity Version 2, Delivered 4/06/17 BULK Option to perform action in bulk Account Creation Account Setup Next Steps Preceding Journey N/A Individuals who are licensed, or have an intent to become licensed, will be assigned an NMLS ID at account creation. Subsequent Journey #1 - Pre-Licensure Requirements (Individual Licensee) Mary searches for how to apply for a license, and is directed to the NMLS website to find a clearly defined set of 'quick links' which includes setting up a new account. Mary is asked a series of questions to guide her to the right account type she wants to register for, in this case individual licensee. The questions include asking Mary what business activities she will be engaging in to drive dynamic display. Mary is prompted to input basic information about herself The system validates Mary's basic identifying information against external data sources and against rules to prevent duplication (e.g. duplicate addresses). If there are no issues, then Mary's account is created. If there are any issues or red flags, Mary cannot continue and is presented with the reason why. If she feels there is an error (e.g. someone used her address without her knowledge), she can submit a request Mary receives a login and password in her and logs into NMLS for the first time. She changes her password, sets security questions for selfservice password reset, and includes a personal address for account recovery. She is required to confirm her personal address. Mary completes her own personal profile information such as address, phone number, etc. Since she does not enter an employer, Mary is prompted with a notice that not all states allow her to move forward without an employer. Most states allow this with the license moving to an inactive status after being approved. After completing the account set up, Mary is presented with options regarding what she would like to do next. (e.g. SSN) for validation. for review. User Experiences: Mary I am able to view detailed and easy-to-use instructions on how to create an account. Mary A complete list of all the information I need to create an account is included right on the screen. Mary If I have a question while I am creating an account, I can access specific help resources right on the screen I am working on. Mary I can change my password without having to call the contact center. Mary Mary selects the option to apply for one or more state licenses. A guided process begins to walk her through next steps, such as selecting the license she would like to apply for, understanding what the pre-licensure requirements are, and entering the information / uploading the documents that are required and will be used later in her filing. The system automatically validates the information that I enter, such as my SSN, address, etc. Mary Personal profile information will be automatically pre-populated into state filings later. Mary The system cross-references data to ensure consistency across records. Mary The system walks me through the process of setting up my account. Mary The system performs a completeness check and notifies me of any missing information before allowing me to complete the records. 128

131 #43 - Account Creation (Individual Licensee) NMLS 1.0 Pain Points: Difficulty locating help resources on the Resource Center. The account request process is currently done outside of the system through the call center. The system doesn't validate if a user already has an account, leading to the creation of duplicate accounts. Profile information is not validated against third party data sources. Individuals without a SSN have challenges receiving an NMLS ID. addresses are not validated and sometimes users will enter an incorrect address. There is no ability to auto-fill filings which leads to entering data that is already in the system. NMLS 2.0 Capabilities: Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, EIN, addresses, etc.). Ability to have a single login/profile, with access and association to multiple entities. Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to notify users via . (e.g., NMLS login credentials). Ability to reset password without calling the Contact Service Center. Ability to attach personal details to personal profile, such that changing companies does not invalidate certain personal details (e.g. valid fingerprints). Ability to capture multiple addresses (work and personal) in a user profile. Ability to suggest properly formatted addresses upon received error (any bulk uploads / API integrations). Ability to validate that addresses are consistent across filings. Ability to indicate what fields are required prior to entry and after form submission (if required fields were omitted). Ability to check submitted forms for completeness against requirements and provide immediate user feedback on gaps/errors/omissions. Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication (e.g., streamlined, intuitive user interface). 129

132 NMLS 2.0 Journey Map Engagement Journey Map 43 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry General Question?: In addition to Mary, can there also be an option / workflow for companies to have the ability to create accounts for newly hired team members? This would be helpful when creating 100+ accounts on a monthly basis and would be a huge efficiency play in saving time. 1. Bulk capability exists 2. Option to skip prompted questions exists 3. Address validation for individuals would not prevent an account from being created. Flagged for Future Response Step 2: Question?: Before Mary is asked a series of questions, can there be a question for the licensee to inquire if they already know the type of account they want to set up? If yes, can we eliminate the series of questions having to be answered. Step 3: Question?: In the map, it indicates that the system will validate Mary s identifying information against external data sources. With regard to the address validation, what happens if the system cannot validate the address (i.e. we tend to see this sometimes with newly built homes for a small period of time until registered)-will the system allow Mary to continue? Or will there be some sort of flag to indicate this and still allow her to move on? Industry This is for an individual on their own to set up, but will there be a journey map (or maybe there is already) for the company to set up a brand new individual and complete all the necessary steps? Yes this journey exists (Journey Map #15.)

133 NMLS 2.0 Journey Map Engagement Journey Map 43 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Account Creation, Item 2: Will this step include questions to direct Mary to a state licensing versus federal registration page? We definitely agree that the account creation process should be updated to account for individuals without a U.S. social security number. It is not readily apparent that the 2.0 updates actually do this, even though it is identified as a pain point (based on our review of the slides), but given not only instances of foreign control persons but also the increase in third party loan processing and underwriting companies located offshore, the NMLS should seek simpler ways to address creating an NMLS account for a foreign individual. Additionally, we think that the NMLS should be more transparent in how foreign individuals can create special accounts to ensure that system-imposed processes (like the credit report authorization) do not automatically block them from attesting to an MU2. In our experience, figuring out how accommodate a foreign control person on the NMLS involved multiple lengthy calls to the call center, and the guidance we received from one representative to the next was not always consistent. Further, requisite forms and materials for addressing these situations are not posted publicly on the NMLS Resource Center is there a reason for this? 1. Entity type will be determined during Account Creation 2. The review of the process for setting up Foreign Entities is currently underway. This currently includes fields specific to foreign nationals, ability to upload documents, etc. Flagged for Future Response Regulator For Map #43, step #5: Has there been any thought about moving the warning about the inability to apply for an inactive license to Step #7 instead? This would (1) allow states to set their license setting to allow or not allow for submission without an employer/sponsor and (2) allow Mary to know the specific requirement of the state she's applying in rather than a generic message which may discourage her from applying inactively in a state which allows for inactive status. Alternatively, if the notice is kept in Step 5, can the individual at least be presented with a list of states that do or do not allow for inactive status so they can review the specifics? The format of process flow has changed somewhat to put the license selection at the end. Surrounding this would be a selection wizard that would help guide users to the proper license options based on a variety of input.

134 NMLS 2.0 Journey Map Engagement Journey Map 43 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry What happens is the license type chosen is wrong or not a license that the company has? o There should be a refund or ability to switch the license type after submission if the individual chose wrongfully. New individuals coming into the industry will not know their future company only accepts the CA DBO and not CA DFI, etc. If not a refund, there should be an option where the individual s account is credited the amount spent to obtain the incorrect license. There could also be a warning or stop before the purchase. There has to be some information given to the applicant during this process. Surrounding this process would be a selection wizard that would help guide users to the proper license options based on a variety of input. That includes specific questions/precautions around California (and other complex state choices). The goal is to dramatically reduce incorrect license choices. Flagged for Future Response Regulator It would be great if it stopped the person from submitting the application if they did not have an employer since we will not approve an individual unless they are sponsored by our state licensee. Obviously make that a state-specific setting since other states place individuals into "approvedinactive" status if they do not have a current employer. Great idea for a license specific setting on what constitutes a "complete" application - we will add it!

135 NMLS 2.0 Journey Map Engagement Journey Map 43 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry Question?: If a duplicate account appears, can you please show the NMLS# and/ or Name of individual? This can already be searched for in the consumer access site by individual name but giving the NMLS# can allow the individual a quicker ability to see if they already have an account or if there is a problem. Step 4: Question?: At this point, is it possible for Mary to have the ability to customize the type of notifications she receives? This would preferably include the ability to come back and update the notifications as needed. No Step # - We are working on a way to provide adequate information to identify the issue - whether that is providing the admin user with information or ensuring that a support ticket is automatically generated to resolve it. 4. TBD ( branding requirements) 5-7. We will try to ensure that admins can act on behalf of users as much as possible Flagged for Future Response Step 5-7: Question?: In some cases, it is the company who is choosing the state licenses needed for the individual. Is it possible, in these next few steps, Mary can skip, logout, and come back to once the states are identified? In those cases where the company decides (and pays) for the licensure, we would not want the MLO having the ability to choose the state on their own based on the fact licensure is delegated out via company need.

136 #44 - State License Filing Submission for an Individual Seeking Licensure Personas: Journey Map Mary Individual Licensee Sam Regulator Account Administrator (State) Background: Human activity System activity Version 2, Delivered 4/06/17 Mary completed all of the pre-licensure requirements in the previous journey, such as populating the core data, uploading required documents, and completing the professional standards requirements such as prelicensure education, testing (e.g., SAFE Act), getting fingerprinted, and authorizing a credit check. Mary now wishes to begin the filing. A guided process begins to walk Mary through the filing process, and the filing is automatically populated from the core data that Mary entered while any required documents are automatically attached from the document repository. After completing the filing, Mary attests and submits payment, and the filing is sent to the applicable state regulator (Sam) for review and approval. BULK Option to perform action in bulk Preparation Preceding Journey(s) #43 - Account Creation (Individual Licensee) #1 - Pre-licensure Requirements (Individual Licensee) Submission Review and Approval Subsequent Journey(s) #8 - State Regulator Review of Individual Licensee Filing Mary completed all of the pre-licensure requirements in the previous journey and now wishes to begin the filing. A guided process begins to walk Mary through the filing process. User Experiences: If Mary has yet to complete any of the professional standards requirements, the system requires her to complete them before submitting the filing. The application s core data is automatically populated by pulling information from Mary s profile (e.g., address, date of birth, work history, disclosure questions etc.) that was entered during the prelicensure requirements journey. Mary entered 'no employer' while entering her core data, and this is also populated in her filing. Mary confirms the pre-populated core data and completes any additional information that was not automatically populated. Required documents contained in the document repository are automatically attached to the filing (e.g., personal identification, disclosure question explanations). Mary is prompted to submit any additional state-specific requirements directly in the system. Mary completes the filing, attests to all information, and submits payment. The filing is submitted to the state regulator for review. Requests for Mary's CBC and credit report are automatically submitted. Mary receives a notification that her filing has been submitted. If the filing triggers any configurable system flags (e.g. CBC doesn't match the disclosure responses), Mary receives a notification to correct the discrepancy prior to the filing being submitted to the regulator. Mary tracks the status of the application within NMLS. If necessary, she responds to any action items placed by Sam (Regulator) or provides additional information. When applying for a license, the guided process walks me through the filing step-bystep. I am able to quickly and easily navigate throughout the different sections of the filing and the onscreen status bar keeps track of my progress. The system pre-populates my filing by pulling information stored in my record. Mary Mary Mary Mary I am able to complete all steps of the application filing process within NMLS, including communicating with other users and uploading/ submitting all documents. Mary receives confirmation that the application has been approved or denied. Mary now continues her job search. The system performs a completeness check and notifies me of any missing information before allowing me to submit. If I have a question while I am completing the filing, I can access specific help resources right on the screen I am working on. I can come back to the filing later and my information will be saved, even if I get timed out. Mary Mary Mary Mary I am able to track the status of my application after submitting and have insight into where in the review process my application stands. 133

137 #44 - State License Filing Submission for an Individual Licensee With No Employer NMLS 2.0 Capabilities: NMLS 1.0 Pain Points: Licensees are often unsure of where to start in the licensing process. The application workflow is complex, not intuitive, and does not provide transparency on where the applicant is in the process. Varying state checklist requirements (which are external to the NMLS system) create confusion during the application submission process. Difficulty locating help resources on the Resource Center. Applicants are unsure of the status of their application after submitting. Unable to communicate with other users in the system. Ability to combine logical workflow components to facilitate the user experience and reduce confusion/duplication (e.g., streamlined, intuitive user interface). Ability to see progress while completing the filing (e.g., visually represent with a status bar where the user is in the overall application workflow). Ability to re-use background and credit checks that are stored in a user's record. Ability to leave and come back to a filing and resume in the same location (i.e., save and continue). Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to include State Agency requirements and allow State Agencies to edit these requirements. Ability to assist users with a step in the process based on the stage of the process and also directly on the page (i.e., contextual help resources). Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to upload multiple files at one time. Ability to tag documents with metadata in the document upload section based on workflow and context. Ability to provide e-signature capability for any forms / documents requiring a signature. Ability to upload documents for review by the selected state licensing authorities. Ability to communicate with other users within the system. Ability to assign tasks to individuals/groups. Ability to make multiple payments in one invoice similar to a shopping cart concept. Ability to have insight into state regulator review progress. 134

138 NMLS 2.0 Journey Map Engagement Journey Map 44 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry With 2.0 they have increased functionality which allows them to upload documents, populate Core data, PE, Testing, Credit, and then the filing is automatically populated from the core data at time of application. Under 1.0 they can do everything except getting finger printed and credit check prior to application. In 1.0 we cannot see what they have entered as core data or their document uploads prior to submission of the license application. With 2.0 will we be able to see their core data and document repository prior to their application submission once they grant access? This would really help us in assisting them with their questions. Yes, the company organized user will have access to the individual's core data once the individual grants access. Flagged for Future Response Will 2.0 still allow us to see when PE, CE, Testing are complete and if fingerprints are expired? It is important to see this prior to application and renewals submission. Will there be visibility as to fingerprint completion for unlicensed applicants? Industry Industry Even though Mary has marked no employer and is on her own... if there is an employer, ensuring the company gets notification of the applications submitted and edu, testing, FP records if the individual (Mary) in-fact has to submit on their own. Is it possible to have the proof of citizenship, driver s license, name change documentation added in the beginning phases BEFORE the applicant applies for a license? In addition, if the paper clip could assist the applicant with the specific documentation needed based off the specific disclosure question. An applicant brand new to the industry may not know what documentation is needed to satisfy the individual state requirements on what is needed. This is understood that the company needs to know the status and that the various requirements have been met. We are looking at requiring as much information as early in the process as possible. Industry Ability to provide e-signature capability for any forms/documents requiring a signature will all state-specific forms that are required to be sent via hard copy to the regulator now be required to be e- signed in NMLS rather then sending it to the regulator via hard copy? At this time we're still validating if or when there is a need for e-signature by any state. 135

139 NMLS 2.0 Journey Map Engagement Journey Map 44 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Regulator For Map #44, step #8, I agree with Regulator 1 that the presence of a RAP sheet doesn't always trigger a disclosure and that RAP sheets often have no final disposition so a conversation must be had with the applicant. Additionally, if the system is designed to trigger an individual to update disclosures based on data in the system (i.e. credit report, RAP sheet, regulatory actions, adverse license status), I think regulators may want to know. Failure to disclose, intentional or not, is often cited in regulatory actions - I'm sure most states use discretion based on the item(s) failed to be disclosed. Great comments, we will make sure this is part of the detailed discussion. Flagged for Future Response Regulator Step 8: It notes an example of a "system flag" as "CBC doesn't match the disclosure responses" and indicates that a notification is automatically generated for the license applicant. This cannot be a system-generated notification as the presence of a RAP usually does NOT indicate that an affirmative answer to the criminal disclosure questions would be required. A human being needs to review the RAP to determine if information on the RAP would appear to require disclosure. Also, in such cases, an individual needs to reach out personally to the applicant to confirm the disposition of the case and/or the accuracy of the CBC, as the CBC is often incomplete and it is occasionally incorrect. Note that most hits on the CBC are not required to be disclosed (e.g. DUI misdemeanors). Also, the individual does not see their own CBC results. SRR understands the concern. This is still something that is still in the exploration phase of if and how we might be able to do manage this type of system of flag given its complexity. Regulator I feel good about the account creation process. I especially like the ability to send mass notifications (steps 13 and 14. I agree with Regulator 1's comments about CBC and Regulator 2's comments about Approved-Inactive licenses. The maps don't seem to address the possibility of an Inactive license. This is an important piece to an MLO license. Thanks for the feedback. We'll review the approvedinactive question. 136

140 #48 - Employment Relationship Lifecycle (Federal) Personas: Journey Map Matt Individual Registrant Marcel Institution Organization User (Federal) (Institution A) Horace Institution Organization User (Federal) (Institution C) Mildred Institution Organization User (Federal) (Institution B) Employed By Institution A This journey discusses the proposed changes to employment and relationships that will be implemented in 2.0. There will be a concept of "active employment", and a concept of "access". 'Active employment' with an entity means the individual works for that entity and the entity has access to the registrant's record. 'Access' means registrants can grant access to an entity without actually being employed by that entity. If you have an employer and are creating a new account yourself, you can select your employer, which will create a task for the employer's org user to confirm employment. If the employer sets up the account, the employment is confirmed by default. When changing employers, the individual and new employer both must accept the new employment. This journey walks through the full employment relationship lifecycle, demonstrated by the experiences of a prospective individual registrant, Matt. Matt is new to the industry, does not have an NMLS account, and has recently been hired to work for Institution A. The journey details the initial creation of Matt's account and establishment of employment with Institution A. After a few months at Institution A, Matt accepts an offer from Institution B, and grants Mildred access to his record prior to leaving Institution A. After a few months at Institution B, Matt s employment is ended and he remains unemployed for a period of time before being hired by Institution C. Preceding Journey(s) N/A Background: Employed by Institution B Individuals are prompted with a warning message to confirm the end date prior to proceeding Human activity System activity Ending Employment / Unemployment BULK Option to perform action in bulk API API Gateway Version 2, Delivered 5/1/17 Employed by Institution C Subsequent Journey(s) N/A Matt, an Individual Registrant, has recently been hired to work for Marcel's Institution, Institution A. Matt is new to the industry and does not have an NMLS account. User Experiences: Marcel creates an NMLS account for Matt, assigns him the roles and permissions of an individual registrant for the Institution, and enters Institution A as his employer. As his employer, he automatically has access to his record. After logging in for the first time, Matt has a notification that Institution A added him as an employee and his employment record has been updated accordingly. Matt completes his fingerprinting, core data entry, and document upload, and his filing is submitted. After a few months at Institution A, Matt accepts an offer from Institution B, and grants Mildred readonly, limited access to his record prior to leaving Institution A so Mildred can see his record and start the onboarding process. Institution A does not see that he granted access to Institution B. Matt starts working at Institution B and clicks a link on his dashboard to process an employment change, which walks him step-by-step through the process. Matt enters an end date and reason for Institution A, which updates his employment record and removes Marcel's access to his record. Marcel can still see Matt's record for the time he worked at Institution A for historical and exam response purposes. Matt selects Institution B as his new employer, which creates a task for Mildred to approve the employment. Mildred approves, which updates Matt's employment record and roles/permissions to reflect the configuration for registrants for Institution B. Alternatively, Mildred could send an employment request to Matt, which, once accepted, would update his employer and end employment with Institution A. Matt is notified that Mildred approved, and is guided to attest to his employment change. Mildred receives a task on her dashboard to attest and pay for the employer change fee. Matt s employment with Institution B is ended. Mildred enters an end date and reason, which updates Matt's employment record and removes Mildred's access to his record. Mildred can still see Matt's record for the time he worked at Institution B for historical and exam response purposes. Matt is unemployed for several months before being hired by Institution C. Matt's employment record displays a period of unemployment from the time he stopped working at Institution B to the time he starts working for Institution C, unless he held a job in a different industry, in which case he can update his record. Matt clicks the link on his dashboard to process an employment change, and adds Institution C as his new employer. Horace receives a task to approve the employment, which grants him access to Matt's record, and updates his roles/ permissions to reflect the configuration for registrants for Institution C. Matt's employment record is also updated. Alternatively, Horace could have sent an employment request to Matt, which, once accepted, would have granted him access to Matt's record and updated his employer to Institution C. Matt is notified that Horace approved, and is guided to attest to his employment change. Horace receives a task on his dashboard to attest and pay for the employer change fee. Marcel API Horace BULK Mildred I am able to assign tasks to my registrants when establishing an employment relationship. Marcel Horace Mildred I can configure the system to be the default payer for all of my registrants' activities. Marcel Horace Mildred I am able to configure and assign different roles and permissions to users within my Institution. Matt I can reset my password and recover my account without involving my Institution or calling customer support. Matt I can grant access to entities of my choosing, even if they are not my employer. Matt Beginning/ending employment with an entity automatically updates my employment record and access to my record. Marcel Mildred I have access to my employees' records for the time they were employed by my Institution, even after they leave. Marcel Horace Mildred As an employer, I automatically have access to my registrants' records. Mildred I am able to add a reason when ending an employment relationship. Matt The system guides me through the process of changing employers step-by-step. 137

141 #48 - Employment Relationship Lifecycle (Federal) NMLS 1.0 Pain Points: Users are unsure where to start in the registration process. Difficulty locating help resources on the Resource Center. Profile information is not validated against third party data sources. addresses are not validated and sometimes users will enter an incorrect address. Users are able to complete certain actions that their Institution may not want them to complete. The system doesn't validate if a user already has an account, leading to the creation of duplicate accounts. When a Institution is granted access by an individual, they receive a notification that they were granted access, but it does not say who it was that granted access. The filing workflow is complex, not intuitive, and does not provide transparency on where the individual is in the process. There is an insufficient level of granularity when it comes to existing permissions. Users often don't know what exactly they are granting access to when providing access to another user. Unable to communicate with other users in the system. NMLS 2.0 Capabilities: Ability to upload data files from Institution HR systems to perform a validation against data in NMLS (reconciliation between HR systems and employees' NMLS records). Includes workflow and processing to compare uploaded data to NMLS data and provide a screen to decide which version to apply to NMLS (keep/overwrite). Ability to have role-based security access. Ability for users to assign roles and permissions. Ability to request account access from an individual, or individual to grant access. Ability to integrate with third party data sources during data entry/upload to validate data (SSN, addresses, etc.). Ability to reset password without calling the Contact Service Center. Ability to initiate tasks based on user actions, another user's actions (who create a task for you), or system generated activities. Ability to attach personal details to personal profile, such that changing employers does not invalidate certain personal details (e.g. valid fingerprints carry over when changing employers). Ability for individual to grant access to disclosure history (even at other institutions) to their current employer. Ability to assist users with a step in the process based on the stage of the process and also on a page (i.e., context-aware help guides and videos to assist people with the process) help resources should be right on the page. Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to assign tasks to individuals/groups. Ability to function as a real-time system where changes are reflected throughout the application immediately. Ability to send multiple notifications to different parties when actions are taken (e.g. individual is let go by Institution, then individual and Institution could all be notified). Notifications will be logged in audit trail. Ability to provide reminders for scheduled activities or other important dates. Ability to remove access to legal entities after leaving an entity either from ending employment or a change in employment. Ability to view a MLOs record for periods employed (even if individual is no longer an employee). Ability to allow Institution or individual to indicate what a filing was for (e.g. on MU filings) so the filings can be identified later on (Institution level notes). Ability to configure if Institution or individual is primary payer. Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed. Ability for employers to manage an internal employee status (active / inactive, e.g. for military or other roles). Ability to combine logical workflow components to facilitate the user experience and reduce confusion / duplication Ability to see progress while completing the filing. (progress bar) 138

142 NMLS 2.0 Journey Map Engagement Journey Map 48 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Federal Registrants #48 - when an MLO grants access to another institution and discontinues the access of their recent institution will Administrators still receive an advising that the employee removed access to their file? This is planned to be a notification institutions could opt into receiving. Flagged for Future Response Federal Registrants #48 Employment Relationship Lifecycle Step 2/3 owhat is process for submission of fingerprints from our institution vendor? ono reference to institution prefilling the majority of data entry. With data upload from institution, individual would only be required to enter minimal data - answer disclosure questions, employment/address history and verify information. o Filing needs to be sent to institution to be reviewed ( any redline changes, yes disclosure answers, background check results etc) prior to confirming employment. Step 5 - we need to be notified if user terminates employment with our institution. Also concerned about individual s ability to enter reason for termination - should not be allowed to avoid potential to slander a firm. owhat is process for submission of fingerprints from our institution vendor? The process for submitting and receiving prints from institution vendors will not change with NMLS 2.0. The system will permit an institution setting that notes to MLOs that the alternative fingerprint submission processed is used. ono reference to institution prefilling the majority of data entry. With data upload from institution, individual would only be required to enter minimal data - answer disclosure questions, employment/address history and verify information. The plan is to offer an upload template with additional data fields able to be entered. Also, an automated programing interface (API) is planned to be offered. ofiling needs to be sent to institution to be reviewed ( any redline changes, yes disclosure answers, background check results etc.) prior to confirming employment. This will remain the same in NMLS 2.0. Step 5 - we need to be notified if user terminates employment with our institution. Also concerned about individual s ability to enter reason for termination - should not be allowed to avoid potential to slander a firm. Reason for termination will not be added in NMLS 2.0. Institutions will receive notice when an individual terminates employment with them. 139

143 #49 - Mergers and Acquisitions (M&A) (State) Personas: Journey Map Acquisition Overview Jim Company Account Administrator (State) (Company A) Gary Company Account Administrator (State) (Company B) Acquisition Review This journey captures the experiences of two state-licensed companies combining as a result of a publicly announced merger, acquisition, or corporate reorganization. Under the SAFE Act, companies have 60 days from the transaction effective date to complete the transfer of licenses from the acquired to the acquiring company. In 2.0, a streamlined process completed entirely within the system will allow companies to seamlessly complete the M&A process and transfer all licenses. In this journey, Company A has entered into an agreement to acquire Company B, and is therefore responsible for managing the M&A process within NMLS. As only Account Administrators will have access to the M&A functionality, Jim and Gary will perform all M&A required actions on behalf of their companies. As the acquirer, Company A chooses which branches will be retained, and has the option to pick and choose different individual licenses that they will sponsor. Company B's company license will be surrendered, and the licenses that Company A decides not to sponsor go inactive or are surrendered. Note: Acquired companies are responsible for renewing their individual licensees prior to accepting the M&A action if the action occurs during the renewal period. Preceding Journey(s) N/A Sam Regulator Account Administrator (State) Acquisition Background: Human activity Transaction Entry Acceptance Individual Licensee Transfer Discussion point: What will SRR's involvement be in the M&A process? Will M&A require SRR review and / or approval? System activity Attestation/ Payment Version 1, Delivered 4/6/17 BULK Option to perform action in bulk Updates Subsequent Journey(s) N/A Company A has entered into a publicly announced agreement to acquire Company B, with the transaction closing in 90 days. Under the SAFE Act, Company A has 60 days from the transaction effective date to complete the transfer of licenses. A new task is created to initiate the M&A request. Company A fills out the necessary information in the system, which automatically notifies Company B and the associated Regulators. Note: These tasks are created with time-based reminder alerts to mitigate delays. User Experiences: Sam, a Regulator Account Administrator (State), reviews the M&A task and grants approval. Sam would contact Company A and B directly if he had any questions that may have prevented him from granting an approval. Note: Regulator Review may delay the effective date. Jim, Company Account Administrator for Company A, is responsible for managing the M&A process for his company as only Account Administrators will have access to the M&A functionality in 2.0. Jim wants to get a head start on the process, and clicks on the M&A link from his dashboard. A guided wizard begins to walk Jim through the process. Jim indicates he works for the acquiring company. Jim updates any information provided in the initial request (Step 1), and can also enter any notes for Gary, the Company Account Administrator for Company B. Jim I can restrict who has access to the M&A functionality within my organization. Jim Gary receives a task on his dashboard indicating that Company A has initiated an M&A action and selected Company B as the Company being acquired. Gary accepts the M&A access request. I can complete all aspects of the M&A process within the system. Jim immediately gains access to all of Company B's records as well as the list of branches and individual licensees employed by Company B. Jim is then prompted by the system to transfer Company B's branches. Only three branches will remain in business, so Jim selects these three. The system will update these three branch filings with the new company on the effective date. Company B s company license and the remaining branch licenses that will not be retained will be surrendered on the effective date. Jim The system sends employment change requests to all individual licensees at Company B. The notification provides details of the M&A action and tells them that their employer, employment record, and state license will be updated on the transaction effective date. The individual licensee can accept the request, or decline if they do not plan to continue their employment. I don't have to contact the NMLS Call Center to initiate the M&A process. As the individual licensees authorize the future changes, Jim gains access to their records. He is then able to select which licenses he would like to sponsor going forward, with the other licenses moving to an inactive status on the effective date. BULK Jim Jim tracks the acceptances on his dashboard. At the end of each day, Jim adds all of the acceptances into his shopping cart, attests, and pays a single invoice for the employment change fee. On the first day, Jim also includes the one-time base M&A processing fee in the invoice. The system walks me through the M&A process step-by-step. On the transaction effective date, Jim receives a task to confirm that the acquisition is still closing that day. Once confirmed, the employer and employment record is updated for all of the individual licensees who accepted the employment change request. In addition, their license filing is updated with the new employer. The records for Company B and any affiliates that were also acquired are end-dated and can longer be updated. Any individuals who do not accept the employment change request in time will be required to go through the full employment change process including a background check to have their license updated with the new employer. Jim I can enter an effective date in the future when completing the M&A process. Jim The system initiates the employment change requests for me, so I don't have to take any additional steps. Jim I can pay for employment change fees in bulk by adding multiple licensees to a single invoice. Jim The system automatically updates my acquired licensees' employer, employment record, and filing. 140

144 #49 - Mergers and Acquisitions (M&A) (State) NMLS 1.0 Pain Points: M&A does not allow for future dating. M&A does not update any of the record information except employment address. A separate process is needed to update the employee demographic information for M&A activity. M&A needs to be manually accomplished using excel data files and bulk data fixes. The process to initiate M&A is completely manual and done outside of the system. Institutions must contact the NMLS Call Center to obtain the Merger and Acquisition Request Form to start the M&A process. There is a lack of M&A functionality in 1.0. Institutions have to wait for SRR to provide access to the M&A functionality before they can start the process. Regulators are unable to formally review M&A within the system. NMLS 2.0 Capabilities: Ability to make multiple payments in one invoice similar to a shopping cart concept Ability to remove access to legal entities after leaving an entity either from termination or change in employment Ability for company user to send bulk s notifications with the same issue to do something (i.e., accept employment request) Ability to generate an invoice with multiple items. Ability to view a MLOs record for periods employed (even if individual is no longer an employee) Ability to send multiple notifications to different parties when actions are taken (e.g. M&A action). Notifications will be logged in audit trail. Ability to pay invoices on behalf of other users (in bulk) - e.g. company user pays for all company's employees invoices Ability to have role-based security access Ability to function as a real-time system where changes are reflected throughout the application immediately. Ability to track all actions, activities, and changes with an audit trail (e.g., who, what, when, why). Ability for users to assign roles and permissions Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials Ability to assist users with a step in the process based on the stage of the process and also on a page (i.e., context-aware help guides and videos to assist people with the process) help resources should be right on the page Ability to request account access from an individual Ability to have a single login/profile, with access and association to multiple entities. And the ability to identify and change what entity you are working on currently and all entities that you have access to in the system. Ability to check submitted forms for completeness against requirements and provide immediate user feedback on gaps/errors/omissions Ability to easily toggle between one entity and another for which the user has an admin or organization role. Ability to combine logical workflow components to facilitate the user experience and reduce confusion/ duplication (e.g. pay for employer change fees at the time of attestation) Ability to populate form data from existing data in NMLS or based on business rules based on the action being taken or the form being completed Ability to initiate tasks based on user actions, another user's actions (who create a task for you), or system generated activities Ability to automatically update object record data when actions are taken on that object (e.g. update employment record when hired / terminated / transferred) Ability to assign tasks to individuals/groups 141

145 NMLS 2.0 Journey Map Engagement Journey Map 49 User Type Stakeholder Questions Stakeholder Recommendations SRR Response Industry #49 Once Company A gets access to Company B, will Gary lose access to the Company B profile and/or the ability to help with the M&A? Or will only Jim have that ability once M&A is accepted? Will Gary or Jim have the ability to see what individuals have not accepted or declined the employer change? That way one of them can follow-up w/ the individual(s) that are not taking action so to avoid step #12? Is there a system notification to the individual more than once as a reminder in case they forgot to take action? Industry Journey #49 - Mergers and Acquisitions: As noted in Journey #40, many companies rely on a third party for all of their licensing needs. The background information states that only the Account Administrators will have access to the M&A process. In the User Experiences, it states that Jim can restrict access to this functionality within his organization. Does Jim have the option to grant another user, such as a third party user, the ability to access the M&A functionality? If not, why not? Also, if a transaction date is changed, is there a way to change the effective date? We are planning on working M&A later this year and will add these questions for that detailed discussion. Users with appropriate roles (including third parties) will have access to M&A info as we understand many larger transactions involve assistance from these folks. We will update this accordingly. If a transaction date changes, we anticipate they will be able to change the effective date. One of the current "pain points" is how the transactions process as part of ACN-so this will be considered. Flagged for Future Response Regulator Step 2 question relating to SRR review and approval - it is unclear what action is contemplated by SRR in reviewing and approving a change of control (M&A) Good catch. We will address more when we begin work on the requirements for M&A. 142

146 #51 Periodic Reporting (MSBCR) Personas: Background: Journey Map Rick Company Account Administrator (State) (MSB) Sam Regulator Account Administrator (State) This journey captures the user experiences associated with preparing and submitting periodic reports via the system. Specifically, this journey covers the submission of the Money Services Businesses Mortgage Call Report (MSBCR), which consists of activity-based reporting for money services businesses licensees (e.g., money transmitters, check cashers, prepaid, etc.). The two personas highlighted in this journey are Rick, a Company Account Administrator for a Money Services Business (MSB) responsible for submitting the MSBCR, and Sam, a Regulator Account Administrator responsible for reviewing the MSBCR. Some of the key capabilities featured in this journey include: dynamic report display driven by business activities, bulk upload submission, ease of document upload (validation on multiple file upload types), document tagging with metadata, company document storage, version history of uploaded documents, configuration of expiration dates for saved uploads to personal/company profiles, and built in completion checks that avoid reporting errors. Human activity System activity API API Gateway Version 3, Delivered 5/1/17 BULK Option to perform action in bulk Notification Preparation Submission Review Preceding Journey(s) Subsequent Journey(s) N/A #32 - Reporting, Data, and Analytics (Regulator) The system notifies Rick that the MSBCR is available for him to complete. Company users will only see reports specific to their company based on the business activities provided during account creation. In this scenario, Rick's company holds a money transmitter license, so he is notified when the MSBCR is available. He clicks on the link in the notification and a guided process begins to walk him through the report submission. User Experiences: Rick I am able to view the onscreen instructions to prepare to submit my report. Rick I am presented with a list of resources to help me prepare for my report submission (i.e., practice sheets, applicable definitions, etc.). Rick has several options of submitting the report, including manual file upload, secure file transfer, or leveraging his company's API gateway. In this scenario, Rick uses the API gateway which interfaces with his internal systems to transfer the required data for the report. He follows the on-screen guide to create and submit the report. Rick could also assign parts of the report to different users to complete. BULK Rick API I am able to utilize the help button on any page that I am on to review the functionality available to me on that given page. The system provides data validations and specific warning messages if there are any issues during the upload process, and also runs a completeness check. In this case, a specific error is identified with the data. This guided process also provides FAQ's and on-screen help resources along the way to help Rick correct the issue. Rick I am prompted by the system when a report is made available for me to submit. Rick follows the FAQ's to address the issue directly on the screen and the system initiates the various validations again. No issues are found, so the system creates the report components, which Rick attests to and submits the report. Rick The system walks me through a guided process to submit my report. Sam receives a task on his dashboard once the MSBCR has been submitted. The system identifies any flagged items for Sam (e.g., explanatory notes, data mismatches, inconsistencies, or abnormal total amounts). He follows up with Rick for more information, or adds action items, if needed. Sam The system identifies any flagged items for me to focus on during my review. Rick I receive a specific error message when there is an issue with the upload. Rick I am provided with the option to manually input or use a data upload option for the MSBCR reports. Rick I am able to upload my MSBCR data in multiple formats (e.g., XML, CSV). Rick I am able to amend or make changes to a MSBCR after uploading. Rick I am able to make corrections in the system without having to upload the file again. I am able to leverage the system s analytics to help in my review of the report. Sam 143

147 #51 Periodic Reporting (MSBCR) NMLS 2.0 Capabilities: NMLS 1.0 Pain Points: On April 1, 2017, the Money Services Businesses (MSB) Call Report was released in NMLS. Pain points with the report will be documented moving forward. Ability to accept multiple file types. For example: [Doc upload] jpg, pdf, doc, xls [Periodic Reporting] csv and xml. Ability to perform file validations on uploaded files. Ability to indicate what fields are required prior to entry and after form submission (if required fields were omitted). Ability for error comments to be specific (in line help and during periodic reporting uploads). Ability to assist users with a step in the process based on the stage of the process and also on a page (i.e., context-aware help guides and videos to assist people with the process) help resources should be right on the page. Ability to provide access to FAQs, quick reference guides, job aids, training videos and tutorials. Ability to upload multiple files at one time. Ability to upload documents without file size limits. Ability to show and access version history of uploaded documents. Ability for documents uploaded to NMLS to be scanned for viruses prior to being accepted. Ability to store company documents in a central location. Ability to limit access to sensitive documents/data in the system by group/user. Ability to only display the sections that are relevant to the licensee. 144

148 NMLS 2.0 Journey Map Engagement Journey Map 51 Staff User Type Stakeholder Questions Stakeholder Recommendations SRR Response Can we please have a separate journey map for the MSB Call Report? UAAR and MSBCR are two separate reports so they should each have their own journey map. Noted and we'll discuss with PwC. Flagged for Future Response 145

149 #52 - Federal Institution End-to-End Journey Personas: Henry Institution Account Administrator (Federal) Background: Henry, an Institution Account Administrator (Federal), is responsible for his institution's federal registration activities, which means ensuring his institution and individual registrants maintain registration on the federal registry. As the institution is newly established, they have not used NMLS to file for registration in the past. Henry searches for how to register with the federal registry, and is directed to the NMLS website to find the instructions on how to request a new account. After creating an account, Henry will be able to begin all of the necessary registration activities, such as creating the institution record, and submitting a filing for federal registration for his institution. Journey Map Human activity System activity Version 2, Delivered 4/10/17 BULK Option to perform action in bulk Account Creation Account Setup Registration Preceding Journey(s) N/A Subsequent Journey(s) #13 - Federal Renewal (Institution) Henry searches for how to register with the federal registry, and is directed to the NMLS website to find a clearly defined set of 'quick links' which includes setting up a new account. Henry is asked a series of questions to guide him to the right account type to register for, in this case Institution Account Administrator, and is asked if this is for a new institution in NMLS. Henry is prompted to input basic information about himself and his institution (e.g. SSN and EIN) for validation. He is also prompted to add an additional Account Administrator. Henry acquires a credential directly from NMLS s approved multi-factor authentication vendor. The system validates Henry and the institution's basic identifying information against external data sources and against rules to prevent duplication (e.g. duplicate addresses). If there are no issues, then Henry's account and the new institution (if applicable) record are created. If there are any issues or red flags, the request goes to SRR for manual review. Henry receives a login and password in his and logs into NMLS for the first time with his two-factor authentication credential. He changes his password, sets security questions for selfservice password reset, and includes a personal address for account recovery. Henry also completes his own personal profile information such as address, phone number, etc. After completing the account set up, Henry is presented with options regarding what he would like to do next, and selects the option to file for federal registration. A guided process begins to walk him through next steps. User Experiences: Henry Henry I am able to quickly and easily navigate throughout the different sections of the filing and the on-screen status bar keeps track of my progress. The system automatically validates the information that I enter for myself and institution, such as SSN and EIN. Henry Henry When filing for federal registration, the system automatically populates the filing from the institution record. The single login gives me the ability to establish and manage all related institution and individual records. Henry Henry I receive a notification that my filing was successfully submitted. The user interface for entering data is very intuitive and well organized. Henry Henry The system performs a completeness check and notifies me of any missing information before allowing me to submit. The easy-to-follow guided process walks me through all of the steps required to complete my institution filing. Henry Henry Henry is guided through all of the core data entry that is required for the institution record, such as identifying information and contact employee information. This data will be automatically populated into the registration filing. I am provided with a clearly defined set of 'quick links' which includes setting up a new account. If I have a question while I am completing the record, I can access specific help resources right on the screen I am working on. Henry Henry reviews the information to ensure accuracy, attests, pays the federal registration fee, and submits to the federal registry. He receives a notification that the filing was submitted, and the notification contains reminders for next steps (e.g. annual renewal). The institution is assigned an NMLS ID at the time of submission. A complete list of all the information I need to create an account is included right on the screen. 146