Comment on CFPB-2011-0023-0002

Comments to section 1008.105 (d) [regarding pre-licensing education]. The CFPB should consider regulations that provide that Real Estate Finance and Mortgage Brokering and Lending courses taken at an accredited college be automatically approved by the Nationwide Mortgage Licensing System and Registry (NMLS) without need to have the college approved as an education provider and without the need to have the courses approved individually. In California, courses taught at accredited community colleges, state colleges, and universities are approved for the pre-license education requirements for applicants seeking a real estate broker or salesperson license. These college-level courses offer significantly more hours of education than the 20 hours required by the S.A.F.E. Act. A review of the approved course providers maintained by the NMLS shows only two community colleges on the approved list, with three other colleges on the suspended list, having had no courses approved. The reason that so few colleges have gone through the approval process is likely due to the lengthy and expensive approval process imposed by the NMLS. While it may be appropriate for private course providers to be required to complete this approval process, it is unnecessary for accredited colleges to have their institutions and courses approved.