SES Functionality Overview

SES policy on the core functionalities of the system.

Approved 10/20/25

This policy provides an overview of the core functionalities of SES, a component of the System1 and any usage restrictions. It also establishes its governance framework and highlights coordination efforts with sister regulatory organizations to ensure consistent standards that enable effective networked supervision.

Functionality Overview

SES has the following core functionalities:
  1. Supervisory Activities (SAs). SAs encompass examination and/or investigation functionality of Company Users2. Currently, only Company Users with the “Non-Depository” designation can be examined or investigated in SES3. In rare and exceptional cases, SA functionality may be utilized to facilitate enforcement actions against a Company User. This use requires a formal request from a regulatory agency and is contingent upon approval by the NMLS Policy Committee.
  2. Consumer Complaints. This functionality allows regulatory agencies to transmit consumer complaints directly to the Company User identified as the subject of the complaint4. In addition to those designated as Non-Depository, Company Users with the “Depository”5 designation may also be the subject of a complaint in SES.

    SES Consumer Complaints includes a “Non-NMLS Entity” feature, enabling regulatory agencies to create records for Company Users that cannot be identified through standard processes, and lack a license or account in NMLS. This feature is accessible to all agency users and supports state efforts to detect and monitor unlicensed activity.

  3. Business Types. As a component of NMLS, SES oversees the supervision of Business Types and their corresponding Business Activities, which can be accessed here. In addition, to support the Depository designation in Consumer Complaints, the Business Types “Commercial Bank” and “Credit Union” are also included in SES.
Table explaining available and unavailable SES functionalities.

Governance and Oversight of SES

The SRR Board of Managers (the “Board”) holds responsibility for oversight of the System. It reviews and approves key policy and development matters, including budgeting, system expansion, and initiatives that may significantly impact SES functionality. To ensure thorough vetting and governance of SES-related development and policy activities, the Board delegates specific authorities to the following agency groups, as follows:
  • NMLS Policy Committee. Responsible for evaluating and approving SES policy matters. The Committee reports directly to the Board.
  • SES Agency Advisory Group (AAG). Focuses on development-related topics requiring review. The AAG reports to the NMLS Policy Committee.
  • NMLS Lawyer’s Committee. Provides legal review and feedback on significant policy and regulatory issues.

Coordination of Supervisory Standards in SES

SES coordinates supervisory activity development with sister regulator organizations. A cornerstone of this coordination is the SES Library, which houses standardized information requests and procedures. These resources promote consistency and harmonization across state agencies by providing a uniform framework for examination activities. CSBS collaborates with regulator organizations and agency working groups to implement, maintain, and update these standards, as follows:
  • Consumer Finance Standards. Developed, updated, and maintained by the National Association of Consumer Credit Administrators (NACCA).
  • Debt Standards. Developed, updated, and maintained by the North American Collection Agency Regulatory Association (NACARA).
  • • Money Services Business Standards. Developed, updated, and maintained by the Money Transmitter Regulators Association (MTRA).
  • • Mortgage Standards. Developed, updated, and maintained by the Mortgage Standards Examination Working Group, which is overseen by the Non-Depository Supervisory Committee (NDSC). Most of the working group members are also part of the American Association of Residential Mortgage Regulators (AARMR), with which it closely coordinates related initiatives.

Coordination with these organizations occurs on an as-needed basis.

1 The term “System” means the Nationwide Multistate Licensing System and Registry (“NMLSR” and/or “NMLS”) and all examination programs, investigation programs, complaint programs, software applications, materials, content or services accessible thereon, as provided by SRR, affiliates of SRR or other third parties.
2 A “Company User” refers to a covered financial services institution, its branches and subsidiaries, and its affiliated individuals (such as Mortgage Loan Originators).
3 SES derives base record Non-Depository data from NMLS. Therefore, the Company User must have at a minimum an account in NMLS. NMLS validation processes occur within its database, and only after successful validation can the data be imported into SES.
4 SES does not currently offer consumer-facing functionality. The agency must input the complaint they receive externally from consumers in SES before sending it to the company.
5 SES derives base record Depository data from the National Information Center (NIC). NIC is a publicly available repository of financial data collected by the Federal Reserve System. It is managed by the Federal Financial Institutions Examination Council. The data is updated in SES weekly.