In today’s evolving ARM environment, collection agencies are responsible for monitoring changes in licensing regulations and ensuring that they themselves and/or a licensing support vendor, such as Acumen Solutions Group, file renewal applications timely.
It’s not always good enough to just to submit a license renewal application before a deadline. Instead, many creditors have an expectation that their collection agency vendors will have filed license renewal applications long before the current license expires. Managing these expectations and demands requires careful planning and ongoing communications.
With this in mind, we have prepared the following summary to assist creditors, licensees, and Acumen manage licensing expectations in 2017 and beyond.
- Based on our experience, the following is a list of relevant states/licenses currently using the NMLS system for initial and renewal licensing:
• Connecticut Collection Agency License
• Idaho Collection Agency License
• Indiana Collection Agency License
• Massachusetts Collection Agency License
• Montana Consumer Loan License
• North Dakota Collection Agency License
• Rhode Island Collection Agency License
- Based on our knowledge, the following is a list of relevant states/licenses migrating to the NMLS system for initial and renewal licensing:
• Arizona Collection Agency License
• Maryland Collection Agency License
• Oregon Collection Agency License
Note: All the above-referenced states/licenses in NMLS will expire annually on December 31 and are not available for renewal in NMLS until November 1.
- Based on our experience, the following is a list of states or jurisdictions and licenses that currently cannot be renewed until after a notification (letter, invoice, etc.) is received by the licensee:
• Alabama – need renewal notice
• District of Columbia – need renewal notice (LREN)
• Hawaii – need renewal notice
• Illinois – need renewal notice
• Illinois, City of Chicago – need renewal notice (PIN number)
• Maine – need renewal notice
• Nebraska – need renewal notice
• New York, City of Buffalo – need renewal notice
• New York, City of Yonkers – need renewal notice
• Oregon – need invoice
• Washington – need renewal notice (Letter ID) for first time online filing
• Wisconsin – need renewal notice
Note: Renewal notices and applications and/or requirements are subject to change at any time.
- Based on our experience, the following is a list of states or jurisdictions that currently do not accept, provide access to, or make available, renewal licensing 60 days or more prior to the renewal due date:
• District of Columbia
• Illinois, City of Chicago
• New Mexico
• New York, City of Buffalo
• New York, City of Yonkers
• North Carolina
• Puerto Rico
- Based on our experience, the following is a list of states or jurisdictions that typically have delays, sometimes 30 or more days, in reviewing renewal license applications beyond the license expiration date, regardless of when the renewal license application is submitted:
• North Carolina
• Puerto Rico
Note: Some state licensing departments consist of 2 or less employees, employees whose job responsibilities include other functions in addition to collection agency licensing regulation, and/or employees who are responsible for licensing regulation of other industries – consumer loans, insurance, mortgage lending, etc.
For assistance in renewing your licenses, please contact Acumen via email to [email protected].