Texas mortgage companies engaged in third-party loan processing or underwriting have a new quarterly filing requirement on top of the NMLS Mortgage Call Report. The Supplemental Submission for SML Independent Loan Processors — SSSF — took effect with the Q1 2026 filing window, due May 15, 2026, and it introduced four new data fields that require careful reconciliation against your existing origination data.
This article explains what the SSSF requires, who must file, what each of the four fields captures, how to avoid the most common filing errors, and how the Texas SML has signaled it will approach enforcement of the new requirement.
What Is the SSSF and Why Was It Created
The SSSF is a quarterly supplemental filing required by the Texas Department of Savings and Mortgage Lending (SML) for state-licensed mortgage companies operating in Texas. It was developed under the authority of 7 TAC § 56.205 (for residential mortgage lenders) and 7 TAC § 57.205 (for mortgage bankers), with input from industry trade associations and a public comment period that closed in late 2025.
The SSSF responds to a long-standing supervisory gap. Texas is the second-largest mortgage market in the United States by origination volume, and the state has historically had a higher-than-average concentration of independent third-party processors and underwriters serving non-bank lenders and credit unions. The NMLS Mortgage Call Report captures loan-level origination and servicing activity at the company level, but it does not separately identify the activity performed by third-party service providers. The SSSF closes that gap.
For examiners, the SSSF creates visibility into which entities are doing the actual processing and underwriting work, how much of it, and on behalf of which investors or counterparties. For lenders, it adds a quarterly reporting burden — and a new exam risk if the data is not reconciled against other regulatory outputs.
Who Must File the SSSF
The SSSF filing requirement applies to Texas-licensed mortgage companies that, during the reporting quarter, either:
- Performed third-party loan processing services for another mortgage company, OR
- Performed third-party loan underwriting services for another mortgage company, OR
- Contracted with a third party to provide loan processing or underwriting services on the filer’s behalf.
The test is functional, not structural. A company that performs no processing or underwriting for any other party and does not contract with any third-party processor or underwriter is not required to file the SSSF.
For most licensed mortgage companies in Texas, this means the SSSF is mandatory — even if your third-party processing activity is modest. The SSSF threshold is qualitative (any third-party activity at all during the quarter), not quantitative.
The Four SSSF Fields
The SSSF adds four new fields to the existing SML quarterly reporting framework. Two of the fields are mandatory; two are reserved for future use.
SF600 — Third-Party Loan Processing Volume
SF600 reports the dollar volume of loans processed on behalf of third parties during the reporting quarter. The reporting basis is settled loan file volume — loans that reached clear-to-close during the quarter — not application volume. The field is reported in whole dollars.
What counts: Loans where your company performed processing functions on behalf of another licensed mortgage entity. Loans where your company is both the lender and the processor (i.e., you processed your own loan) are excluded — those are reported on the standard MCR.
Common error: Reporting gross origination volume instead of processing volume. SF600 is processing-specific.
SF610 — Third-Party Loan Underwriting Volume
SF610 reports the dollar volume of loans underwritten on behalf of third parties during the reporting quarter. Same settled-file reporting basis as SF600. Loans underwritten for your own portfolio are excluded.
Common error: Counting loans where your underwriting decision was overridden by the investor. The field captures loans for which your company issued the underwriting decision, regardless of whether the loan was ultimately purchased by the investor.
SF630 — Reserved
SF630 is reserved for future use. The SML has indicated this field will capture third-party servicing activity in a future filing cycle. Do not report data in SF630 until the SML publishes the field instructions.
SF660 — Reserved
SF660 is also reserved. The SML has indicated this field will capture investor concentration metrics for third-party-processed or -underwritten loans in a future filing cycle. Do not report data in SF660 until the SML publishes the field instructions.
Filing Mechanics
The SSSF is filed through the existing SML portal — not through NMLS. The filing window is the same as the NMLS Mortgage Call Report, with a due date of May 15 for Q1, August 14 for Q2, November 14 for Q3, and February 14 for Q4 (subject to calendar adjustments for weekends and holidays).
For each quarter:
- Q1 (Jan–Mar) — due May 15
- Q2 (Apr–Jun) — due August 14
- Q3 (Jul–Sep) — due November 14
- Q4 (Oct–Dec) — due February 14
The SSSF is a separate filing from the NMLS Mortgage Call Report, even though the data sources may overlap. Submit the NMLS MCR through the NMLS portal as usual, and submit the SSSF through the SML portal.
There is no grace period. A late filing is a violation. There is no extension request mechanism for routine quarterly filings.
How the SML Has Signaled It Will Approach Enforcement
The SML has been clear that it understands the Q1 2026 SSSF will be a transition cycle, but it has not offered a blanket grace period for the first filing.
In its March 2026 industry advisory, the SML stated that it will not actively pursue enforcement action against lenders who file late Q1 2026 SSSFs unless the late filing is paired with other compliance concerns or an examiner identifies risk factors that warrant accelerated attention. That is a calibrated posture, not a free pass.
The SML also stated explicitly that placeholder filings — submissions containing inaccurate, estimated, or placeholder data intended to meet the deadline — are not acceptable. If you cannot finalize your SSSF data by the deadline, the right move is to file late with a written explanation, not to file on time with bad data.
For Q2 2026 onward, expect normal enforcement. Late filings will be treated as violations, and inaccurate filings are themselves a violation regardless of when they are submitted.
If You Discover an Error After Filing
The SML has indicated that it expects lenders to file amended SSSFs when errors are discovered post-filing, and that self-discovered and promptly amended errors will generally not be the basis for enforcement action. The amendment process is the same as the original filing process — submit a corrected SSSF through the SML portal with a brief written explanation of the change.
What examiners will look at is whether you have a process for identifying and amending errors, not whether your first filing is perfect. Document your amendment process internally so the file is ready when an examiner asks.
Reconciling the SSSF Against Other Regulatory Outputs
The SSSF should reconcile against the NMLS Mortgage Call Report. Specifically:
- SF600 + own-account processing volume should equal total processing activity reflected in your internal operating data.
- SF610 + own-account underwriting volume should equal total underwriting activity reflected in your internal operating data.
- SF600 + SF610 should not exceed the dollar volume of loans reflected in your company’s origination system for the same period.
- The SSSF should reconcile against your internal list of third-party processor/underwriter relationships for the quarter.
If these reconciliations don’t tie, examiners will ask why. Build the reconciliation into your pre-submission QC.
The Most Common SSSF Filing Errors
In our work with Texas-licensed lenders preparing for the Q1 2026 SSSF, the recurring errors are:
1. Filing With Placeholder or Estimated Data
The single biggest risk. The SML has said this is not acceptable. If your books aren’t closed by the deadline, file late with a written explanation rather than file on time with bad numbers.
2. Including Own-Account Processing in SF600
SF600 captures only third-party processing volume. Loans you process for your own portfolio or on your own behalf are not in SF600.
3. Reporting Application Volume Instead of Settled File Volume
SF600 and SF610 are settled-file metrics — loans that reached clear-to-close during the quarter. Application volume is a different number.
4. Treating the SSSF as Part of the NMLS MCR
The SSSF is a separate filing through the SML portal. Submitting SSSF data through the NMLS MCR portal is not a valid filing.
5. Missing the SF630 and SF660 Reserved Fields
Do not enter data in SF630 or SF660. They are reserved for future use. Entering data there will trigger a validation error and may be flagged as an attempted misrepresentation.
Building a Sustainable SSSF Process
A defensible SSSF process has three core elements.
Quarter-End Data Snapshot
Take a clean snapshot of third-party processing and underwriting activity at the end of the reporting quarter. The snapshot should include loan-level data: counterparty, dollar volume, settled file vs. application status.
Pre-Filing Reconciliation
Before submission, reconcile SF600 and SF610 against your internal operating data and against the NMLS MCR for the same period. Any unresolved difference needs an explanation and a documented path to resolution.
Documented Amendment Procedure
Write down how you will identify, document, and file amendments when errors are discovered post-filing. This is the process examiners will ask about, and it is the process that turns a one-off error into a tolerable compliance event rather than an enforcement trigger.
Frequently Asked Questions
I Had No Third-Party Processing Activity in the Quarter. Do I Still File the SSSF?
Yes — but with zeros in SF600 and SF610. The SSSF is a quarterly filing requirement that applies to all Texas-licensed mortgage companies that had any third-party activity in the most recent four quarters, regardless of whether the current quarter had activity.
I Contract With a Third-Party Processor but Perform No Processing for Third Parties. Am I in Scope?
Yes. The SSSF captures both inbound (you contract for third-party services) and outbound (you provide services to third parties) activity. If you contracted with a third party during the quarter, you file the SSSF.
How Does the SSSF Interact With the MCR Examination Process?
The SML has stated that SSSF data will be incorporated into the standard MCR examination work. Examiners will reconcile SSSF data against the NMLS MCR, your internal origination data, and your third-party counterparty records.
What If I File Late and Self-Report?
For Q1 2026 specifically, the SML has indicated it will not actively pursue enforcement for late filings absent other concerns. For Q2 2026 onward, late filings are violations regardless of whether they are self-reported. Self-reporting is still the right move, but expect standard enforcement treatment.
Need help preparing your first SSSF filing? Synergy supports Texas mortgage lenders with data mapping, reconciliation, and pre-filing QC for both the NMLS MCR and the SSSF. Book a 30-minute compliance call.
