As many of us look forward to our summer vacations, the NMLS also has plans to take time off this summer. Due to system maintenance, beginning Wednesday, July 21 at 8:00 p.m. ET, the NMLS and NMLS Consumer Access will be unavailable for four full days, July 22 through July 25, with an anticipated return to operations on Monday July 26 at 7:00 a.m. ET. This maintenance period is significantly longer than previous maintenance periods, which typically occur over a weekend. The system will be completely inaccessible during this time, meaning that all Company and Individual users will be unable to log into their record to make any filings or amendments to the record, or to review any status updates or licensing deficiencies. Regulators also will be unable to access the NMLS or NMLS Consumer Access during this maintenance period. The NMLS Call Center will remain open during the system maintenance.
Below, we offer a few suggestions for users to ensure you and/or your Company are ready for the upcoming NMLS maintenance period:
- Review any pending MU1, MU2, MU3 and MU4 filings in NMLS. Submit what you can before 8:00 p.m. ET on July 21, 2021. Print a redline of any pending filings that are not quite ready for submission. The Conference of State Bank Supervisors (“CSBS”) has advised users that the system maintenance should not disrupt any filings that are pending; however, saving a redline as a reference tool is a small step to peace of mind in the event that your pending filing is accidentally deleted in the maintenance process.
- Be aware of any pending Advance Change Notifications (“ACN”) with an effective date between July 21 and July 26. During the down time, users will be unable to extend an ACN effective date. If there is any concern that a deadline cannot be met, or that an ACN will become effective during this time, consider amending the ACN effective date before the maintenance period begins on July 21 at 8:00 p.m. ET.
- For existing deficiency items, confirm any regulator-imposed deadlines can be met. Reach out to regulators in advance of the shutdown to manage expectations regarding existing deficiency items. You don’t want to find out on the morning of July 26 that a deadline has been missed or risk the withdrawal or suspension of a license or registration based on any misunderstanding associated with the maintenance period.
- Monitor test enrollment windows. Users will be unable to enroll in testing during the system maintenance period. If an enrollment window is set to close between July 21 and July 26, sign up for testing before that date to avoid delays.
- Monitor fingerprinting, education, and testing appointments. Any users who have signed up to complete fingerprinting, education or testing between July 21 and July 26 will still be able to complete their appointment. The results, however, will not be reflected in the NMLS until July 26. It is unclear if the results will be made available at 7:00 a.m. ET, or if it will take some time for the updates to download.
Other than the system down time, the NMLS system maintenance should have minimal effect on Company and Individual records. Users logging into the system on the Monday morning of July 26 should not find any changes to their records, and will not need to complete additional actions to update their Company and Individual records upon regaining access to the system. That being said, taking note of our suggestions listed above could save users some time and aggravation in the event that the system maintenance does not go as planned. Let’s all hope for the best on July 26, and that a minor sunburn is all the NMLS has to show after a few days off.