December 5, 2025
To our valued industry partners and respected colleagues within the Industry, State Members, NMLS Policy Committee, and the Conference of State Bank Supervisors (CSBS),
The Board of Directors of the American Association of Residential Mortgage Regulators (AARMR) would like to address recent concerns and questions regarding a grace period to the Mortgage Call Report Form Version 7 (MCR FV7) in response to which the AARMR Board recently encouraged state regulators to offer a grace period for the Q1 2026 filing submission to the extent that their statutory and regulatory framework will allow. AARMR also encourages member agencies to consider allowing licensees who have made good faith efforts to submit accurate Q1 2026 reports the opportunity to amend their reports, without penalty, if errors are subsequently discovered, to the extent that an agency has such discretion. We want to be clear that AARMR fully supports and respects the NMLS Policy Committee’s decision to move forward with FV7 and its established implementation date. We view this upgrade as essential and beneficial to both regulators and the mortgage industry as a whole.
At the same time, the AARMR Board is encouraging state regulators to consider providing reasonable grace to the industry as organizations work to align their systems and processes with the new requirements found in FV7. This suggestion does not alter the official implementation date, but rather acknowledges the practical operational, programming, and system challenges that often accompany these changes.
AARMR firmly believes in the value of CSBS, the importance of coordinated national form modernization, and the long-term benefits that FV7 will provide to improve data quality, regulatory insight, and consistency across jurisdictions. These updates are necessary, and they serve to strengthen the regulatory ecosystem for both industry participants and state oversight agencies.
The AARMR Board is confident that the same collaborative success achieved during the rollout of FV6 can be realized with FV7. While FV6 introduced broad and complex changes, the updates contained in FV7 are comparatively modest and largely centered around mortgage servicing elements. Many of the new data requirements align closely with information already reported in the Mortgage Bankers Financial Reporting Form (MBFRF). To support industry readiness, CSBS provided the XML specifications for FV7 on October 31, allowing added lead time for development efforts. Additionally, CSBS plans to provide a January 2026 testing option within NMLS for companies seeking to validate XML submissions prior to the Q1 filing period and intends to host a series of “Office Hours” from November 2025 through April 2026 to address questions and assist with FV7 implementation.
AARMR believes strongly in the mission and work of CSBS, and we view coordinated modernization efforts as essential to ensuring regulatory consistency, transparency, and effectiveness. We also recognize that successful adoption requires partnership. The industry demonstrated this with exceptional professionalism during the transition to FV6, producing timely and highly accurate MCR filings. Likewise, state regulators demonstrated flexibility, understanding, and a commitment to shared outcomes. We are confident that the same level of success can be achieved this year as we continue working together toward a more effective national reporting framework.
This position recognizes that the development of the MCR and deployment into the NMLS is handled as a multistate process through CSBS, but the states are the ones with the actual authority to require companies to file the report and enforce the filing. Thus, it is on the states to decide if there will be any grace given in the enforcement of filing.
We remain grateful for the productive relationship we share with the NMLS Policy Committee and CSBS and look forward to many years of continued collaboration. AARMR is committed to transparency, cooperation, and supporting both the regulatory community and the mortgage industry as we collectively build a better and more efficient system.
Sincerely,
The AARMR Board of Directors
The American Association of Residential Mortgage Regulators is a non-profit corporation whose mission is to promote the exchange of information and education concerning the licensing, supervision and regulation of the residential mortgage industry, to ensure the ability of state mortgage regulators to provide effective mortgage supervision for a safe and sound industry meeting the needs of the local financial markets and to protect the rights of consumers.