The best way to analyze the requirements is to parse, line by line, the requirements as outlined on the NMLS Company Licensing Checklist. The single most important element in this process; the company must correctly identify the document and relate it to the explicit request. For example, if the regulator requests a business plan, you must follow their taxonomy to the letter; This document should be named [Company Legal Name] RM Business Plan.
Ohio Business Plan Requirement
When the request asks for a business plan, often our customers confuse this with an actual "SBA Style" business plan, laying out the ways and means of a business, such as this one. However, this is NOT what they want. Instead, answer the questions on a single document that identifies the answers.
Ohio Business Continuity Plan
A Business Continuity Plan is a "Disaster Recovery Plan." This is part of our Information Security Plan, which makes sense because we rely on technology more than physical presence to operate our business.
Ohio Company Staffing and Internal Policies
This requirement is an example of how a complex requirement is oversimplified.
- Internal Audit - is usually the quality control plan, but this refers to an annual quality control review, where all areas of operation are reviewed. Print the Annual Operating Audit from the Quality Control Plan and name it "Staffing and Internal Policies - Internal Audit Plan
- The schedule of all compliance issues is addressed in the Compliance Module under Compliance Officer Duties where we detail all of the Compliance Manager's daily, weekly, monthly, quarterly, and annual duties. Print the Schedule of Compliance Manager's Duties to *.pdf and name it "Staffing and Internal Policies - Schedule of all compliance issues."
- PATRIOT Act and Bank Secrecy Act Policies apply to Fraud Detection and Reporting in Quality Control. Print the entire AML policies and procedures, naming it "Staffing and Internal Policies - PATRIOT Act-Bank Secrecy Act."
- Information Technology is the IT Security, Safeguarding, and FACTA Red Flags Plan. Print the entire module and name it "Staffing and Internal Policies - Information Technology."
- Consumer Complaint Resolution Policies are in the Compliance Policies and Procedures Module at the end. Print this section and name it "Staffing and Internal Policies - Consumer Inquiries and Grievances."