To get a mortgage company licence in the US, a non-bank applies to each state where it will broker, lend or service home loans, through the Nationwide Multistate Licensing System (NMLS). Each application combines a company form, individual forms for owners and officers, a qualifying individual, financial statements that meet the state's net worth minimum and, in most states, a surety bond. NMLS charges US$120 per state company licence on top of state fees, which vary widely: a Texas mortgage company licence costs US$325 to apply for and a New York mortgage banker licence US$3,000. Every licence then renews between 1 November and 31 December each year.
There is no federal company licence. The SAFE Act of 2008 sets a federal floor for licensing individual loan officers, and federal consumer rules apply to the business, but the authority to operate comes from each state. This guide sets out the steps in the order a well-run application follows, with the fees, figures and dates verified on NMLS, CFPB and state regulator sources as at 20 October 2026. For the licence summary, see our US mortgage company licence page.
Step 1: Decide which licence you need in each state
States license three activities, and draw the lines between them differently.
| Activity | What the business does | Examples of state licence names |
|---|---|---|
| Brokering | Takes applications and arranges loans that another lender funds | Florida mortgage broker licence; New York mortgage broker registration; Washington mortgage broker licence |
| Lending | Makes and funds the loan in its own name | Florida mortgage lender licence; New York and Wisconsin mortgage banker licence; Pennsylvania mortgage lender licence |
| Servicing | Collects payments, runs escrow and handles arrears | Florida servicing endorsement; New York mortgage loan servicer registration; Pennsylvania mortgage servicer licence |
| Combined | One licence for lending and servicing | California DFPI Residential Mortgage Lending Act licence |
Start with a state-by-state map of where borrowers and properties will be, which activities the firm will carry out in each, and which channels it will use. The NMLS License Requirements and Fees Chart lists every licence type with its fee, net worth figure and bond, and each state publishes a checklist in NMLS. A lender that keeps the servicing rights on loans it makes usually needs servicing authority as well.
Step 2: Build the company record in NMLS
The application is built from linked forms. According to the NMLS licensing process overview:
- Form MU1 is the company's core record: legal name, addresses, business activities, owners, officers and qualifying individuals.
- Form MU2 is filed by each direct owner of 10% or more of a class of voting securities, each executive officer, each qualifying individual and each branch manager. Each person needs their own NMLS account and attests to their own form.
- Form MU3 is filed for each branch office that conducts licensed activity, with one branch record per physical address.
- Form MU4 is each loan officer's individual licence application.
The qualifying individual is the person each state holds responsible for the licensed business. States use different names for the role and set their own experience, education or testing standard. Florida, for example, requires every mortgage lender to be run by a principal loan originator who is a licensed loan originator, and every branch to be run by a licensed branch manager. Choose this person first. If they do not meet a target state's standard, the application in that state cannot proceed.
Step 3: Meet the state's capital and bond requirements
Lender and servicer licences usually require a minimum net worth, shown in financial statements of the type the state specifies: audited, reviewed or compiled. Most states also require a surety bond, which is a guarantee from an insurance company that pays consumers or the state if the licensee breaks the law. Bonds are filed electronically in NMLS.
| State and licence | Minimum net worth | Surety bond |
|---|---|---|
| California DFPI, Residential Mortgage Lending Act | US$250,000 tangible net worth at all times | US$50,000 to US$200,000, by prior-year volume |
| Florida, mortgage lender | US$63,000, or US$250,000 with a servicing endorsement | See state checklist |
| Georgia, mortgage lender | US$100,000 | US$250,000 |
| Georgia, mortgage broker | US$50,000 | US$150,000 |
| Illinois, residential mortgage licence | US$150,000 audited for lending or servicing; US$50,000 compiled for brokering with an in-state office | From US$25,000 |
| Wisconsin, mortgage banker | US$250,000 | US$300,000 for the main office and up to 5 branches, plus US$10,000 per further branch |
| Washington, mortgage broker | Not required | From US$20,000, reset by 31 March each year |
Sources: California DFPI, Florida Statutes s. 494.00611, Washington DFI and the NMLS chart.
Plan the capital for the hardest state on the list, not the first. Net worth must be kept at all times, not only on the day of application, and statements are refiled every year.
Step 4: License the loan officers
Every individual who takes applications or negotiates loan terms for the company needs their own state licence as a mortgage loan originator (MLO). The minimum standard under the SAFE Act and the CFPB's Regulation H is:
- at least 20 hours of NMLS-approved pre-licensing education
- a score of at least 75% on the SAFE MLO Test
- fingerprints for an FBI criminal background check and a credit report, both through NMLS
- no MLO licence ever revoked, and no felony in the previous 7 years, or ever if it involved fraud, dishonesty, breach of trust or money laundering
- sponsorship of the licence by the licensed employer in NMLS
An experienced loan officer moving from a bank or from another state can often start under temporary authority for up to 120 days while the new licence is pending. Our guide to MLO licensing under the SAFE Act covers education, the test, sponsorship and renewal in detail.
Step 5: Put the federal compliance programme in place
State examiners review the licensee's books and records, and the federal consumer rules apply from the first application. The core set is:
- RESPA (Regulation X): no fees or kickbacks for referring settlement business, and detailed servicing rules on escrow, error notices and borrowers in difficulty.
- TILA (Regulation Z): the Loan Estimate within 3 business days of an application and the Closing Disclosure at least 3 business days before closing; loan officer pay that does not depend on loan terms; the company and loan officer names and NMLS IDs on the application, the Loan Estimate, the Closing Disclosure, the note and the security instrument.
- ECOA (Regulation B): no discrimination, and a decision notice within 30 days of a completed application.
- HMDA (Regulation C): non-bank lenders with an office in a metropolitan area that made at least 25 closed-end loans, or 200 open-end lines, in each of the two prior years report loan data by 1 March.
- Bank Secrecy Act: since 16 April 2012, non-bank residential mortgage lenders and originators must run an anti-money laundering programme and report suspicious transactions of US$5,000 or more to FinCEN.
Write these into a compliance manual before filing. State examiners review a licensee's books, records and policies after approval, and the loan officers are tested on the same laws in the SAFE MLO Test.
Step 6: File, answer licence items and go live
Once the forms are complete, the company attests to the MU1, pays the NMLS and state fees and submits. Some states also require documents sent outside NMLS within a set period. The regulator then reviews the file and posts licence items in NMLS, which are requests for documents or explanations. Each must be answered before approval.
Most states do not publish a fixed review period. Florida is an exception that shows how a statutory clock works: the regulator must flag errors or omissions within 30 days of receiving an application, and approve or deny within 90 days of a complete one. Under Florida law, an application counts as received only when NMLS has delivered the form, criminal history results, credit report and fees.
When the licence shows as approved in NMLS, sponsored MLOs can originate in that state and the company appears on NMLS Consumer Access, the free public register.
What it costs
| Item | Amount |
|---|---|
| NMLS company licence fee | US$120 per state licence, on application and at each renewal |
| NMLS branch licence fee | US$25 per state licence |
| NMLS MLO licence fee | US$35 per state licence |
| FBI background check and credit report | US$36.25 and US$15 per individual filing |
| SAFE MLO Test | US$110 per attempt |
| California DFPI application | US$1,000 (US$100 investigation and US$900 filing) |
| Florida mortgage lender application | US$500 |
| Illinois residential mortgage licence application | US$2,700 |
| New York mortgage banker application | US$3,000 |
| Texas SML mortgage company application | US$325 |
NMLS fees rose on 1 March 2025, the first increase since NMLS launched in 2008. Card payments carry a 2.5% service fee. Add the cost of audited or reviewed financial statements, bond premiums and the capital held as net worth. Professional fees for preparing and filing the application are a separate item; at Regulatory Counsel they are a fixed fee set out in a written proposal.
How long it takes
| Stage | What happens | Who sets the pace |
|---|---|---|
| Preparation | Entity, owners and qualifying individual confirmed; statements, bond and policies ready | The applicant |
| Filing | MU1, MU2 and MU3 forms submitted; fingerprints and credit reports processed | The applicant and NMLS |
| Review | Licence items answered; Florida decides within 90 days of a complete file | Each state |
| Loan officers | Education and test first; temporary authority of up to 120 days where eligible | The individual and each state |
The variable that most often decides the total is preparation: a file with a qualifying individual who meets every target state's test, statements that already show the right net worth, and owners who have completed their MU2 forms moves faster in every state at once.
After approval: renewal and reporting
Licensing is the start of a recurring calendar. Every company, branch and MLO licence renews in NMLS between 1 November and 31 December, and a licence not renewed by 31 December expires. Licensees file the Mortgage Call Report within 45 days of each quarter end, so the third quarter 2026 report is due by 14 November 2026. Annual financial statements go into NMLS within 90 days of the fiscal year end. Our guide to the NMLS Mortgage Call Report and annual renewal sets out every filing and date.
Common reasons applications stall
- A qualifying individual who does not meet the state's standard. Check every target state before filing.
- Financial statements of the wrong type. A state that requires audited statements will not accept compiled ones.
- Incomplete individual forms. NMLS updated the MU2 and MU4 disclosure questions on 18 April 2026. Washington DFI has told licensees that a new filing cannot be submitted until owners, officers and branch managers complete them.
- Loan officers acting early. An MLO who originates before the licence is approved and sponsored, outside temporary authority, creates a violation for the individual and the company.
- Unaligned business activities. The activities on the MU1 should match the licences sought and the business done, because they drive what the company reports each quarter.
Regulatory Counsel prepares and files mortgage company applications across states through NMLS as part of our licensing and authorisation service, and supports lenders and brokers through our mortgages and home finance practice.
Frequently asked questions
You need a licence in each state where you broker, lend or service residential mortgage loans, under that state's law. There is no federal company licence and no reciprocity that lets one state's licence cover another.
NMLS charges US$120 per state company licence, US$25 per branch and US$35 per loan officer licence. State application fees are added: for example US$1,000 for California DFPI, US$500 for a Florida mortgage lender, US$2,700 in Illinois and US$3,000 for a New York mortgage banker. Bond premiums, audited accounts and the capital held as net worth come on top.
Most states do not publish a fixed review period. Florida must flag errors within 30 days and decide within 90 days of a complete application. Preparation of the qualifying individual, financial statements and owner filings usually decides how quickly every state can approve.
The person a state holds responsible for the licensed business, sometimes called the qualified person in charge or principal loan originator. Each state sets its own experience, education or testing standard, and many require advance notice before the person changes.
In most states, yes. Examples verified as at 20 October 2026 include US$150,000 for a Georgia mortgage broker and a minimum of US$20,000 for a Washington mortgage broker, reset each year by 31 March based on prior-year volume.
No. An MLO licence must be sponsored by a licensed company, and Regulation Z makes the company responsible for ensuring each loan officer is licensed or registered before they act as a loan originator.
No. Banks, savings associations and federally insured credit unions are exempt from state company licensing, and their loan officers register federally through NMLS under Regulation G.
References
- NMLS: licensing process overview for companies
- NMLS: identifying qualifying individuals
- NMLS: identifying direct owners and executive officers
- NMLS: branch licensing or registration
- NMLS: processing fees
- NMLS: License Requirements and Fees Chart
- CSBS: NMLS processing fee increase takes effect 1 March 2025
- CFPB: Regulation H, 12 CFR 1008.105
- CFPB: Regulation Z, 12 CFR 1026.36
- CFPB: Regulation Z, 12 CFR 1026.19
- CFPB: Regulation B, 12 CFR 1002.9
- CFPB: Regulation C, 12 CFR 1003.2
- FinCEN final rule for residential mortgage lenders and originators (77 FR 8148)
- California DFPI: how to apply for a residential mortgage lender or servicer licence
- California DFPI: requirements after a CRMLA licence is issued
- Florida Statutes s. 494.00611: mortgage lender licence
- Florida Statutes s. 494.00665: principal loan originator and branch manager
- Florida Statutes s. 120.60: licensing decision periods
- Washington DFI: Spring 2026 mortgage and consumer loan industry update
About Regulatory Counsel
Regulatory Counsel is a licensing and compliance practice for regulated finance in 65+ jurisdictions, US first, with more than 200 licence and registration engagements. We prepare and file mortgage broker, lender and servicer applications through NMLS, license the loan officers and set up the compliance calendar that follows approval. Every enquiry is answered the same business day with a written proposal: contact us.
This article is general information as at 20 October 2026 and is not legal advice.
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