Uniform Annual Exam

By ROB ZIMMER As consumers and industry professionals weather a historically difficult housing market, it is more important than ever to foster a mortgage lending environment that supports the continued existence and growth of small lenders. The success of small lenders is not only in the best interest of consumers, but aligns with the goals of Congress and regulators. In 2020, The Conference of State Bank Supervisors launched the State Examination System, which was designed for state regulators to supervise and monitor lenders. While the system is well-intentioned, in practice, these often-overlapping state exams have created proportionately larger costs and time burdens for smaller non-bank lenders (independent mortgage banks or IMBs) that must have licenses in every state they do…