United States

US Mortgage Company Licence: State Broker, Lender and Servicer Licensing Through NMLS

How to license a US mortgage broker, lender or servicer through NMLS: state net worth and bonds, SAFE Act MLO rules, the year-end renewal and the call report.

Licensed state by state through NMLSRenewal 1 November to 31 DecemberCall report 45 days after each quarter

Key dates for 2026 and 2027

18 April 2026PassedNMLS changes the individual disclosure questions and links MLO employment history to company relationships, affecting every MU2 and MU4 filer.
31 August 2026PassedDeadline set by NMLS for companies and individuals to complete the April 2026 updates, to avoid delays in the renewal for 2027.
1 November 2026UpcomingThe NMLS annual renewal window opens for every mortgage company, branch and MLO licence.
14 November 2026UpcomingThe third quarter 2026 Mortgage Call Report is due, 45 days after the quarter ended on 30 September.
5 December 2026UpcomingNMLS SMART deadline for MLOs to finish 2026 continuing education so it posts in time for renewal.
31 December 2026UpcomingRenewal deadline: licences not renewed in NMLS expire and the company must stop licensed activity in that state.
14 February 2027UpcomingThe fourth quarter 2026 Mortgage Call Report is due for all state-licensed mortgage companies.
1 March 2027UpcomingHMDA loan data for 2026 is due from non-bank lenders that meet the loan-volume thresholds.

Written and reviewed by the Regulatory Counsel team. Last reviewed: 20 October 2026.

The short answer

There is no single federal licence for a US mortgage company. A non-bank that brokers, makes or services home loans needs a licence from each state where it does business, applied for through the Nationwide Multistate Licensing System (NMLS), the online system the states share. Every loan officer, called a mortgage loan originator (MLO), also needs an individual state licence under the SAFE Act: at least 20 hours of approved education, a score of 75% or more on the national test, an FBI fingerprint check, a credit report and sponsorship by a licensed employer. Most states also require a named qualifying individual, a minimum net worth, a surety bond (a guarantee from an insurer that pays out if the company breaks the law) and a licence for each branch. Licences renew every year between 1 November and 31 December, and licensees file the Mortgage Call Report within 45 days of each quarter end. Banks and credit unions do not need a state company licence, and their loan officers register federally through NMLS instead.

Key facts at a glance

LicenceA state company licence or registration in each state, usually split into mortgage broker, mortgage lender (also called mortgage banker) and mortgage servicer. There is no federal mortgage company licence
Where you applyNMLS, which the Conference of State Bank Supervisors (CSBS) operates for the state regulators. Company Form MU1, Form MU2 for each owner, officer and qualifying individual, Branch Form MU3 and Individual Form MU4 for each MLO
Loan officer licenceSAFE Act and Regulation H (12 CFR 1008): 20 hours of pre-licensing education, the SAFE MLO Test with a pass mark of 75%, an FBI criminal background check, a credit report, and 8 hours of continuing education every year
Owners and officersDirect owners of 10% or more of a class of voting securities, and executive officers, each file an MU2 and keep their own NMLS account
Net worth, examplesCalifornia DFPI: US$250,000 tangible net worth. Florida mortgage lender: US$63,000, or US$250,000 with a servicing endorsement. Georgia mortgage lender: US$100,000. New York mortgage banker: US$250,000
Surety bond, examplesCalifornia DFPI: US$50,000 to US$200,000 by prior-year volume. Georgia: US$250,000 for a lender, US$150,000 for a broker. Wisconsin mortgage banker: US$300,000. Washington mortgage broker: from US$20,000, reset each year by volume
NMLS feesUS$120 per company licence, US$25 per branch licence and US$35 per MLO licence, charged on application and again at each renewal. Background check US$36.25, credit report US$15, national test US$110
Annual renewal1 November to 31 December every year. Late reinstatement from 1 January to the end of February, only in states that allow it
Ongoing reportingMortgage Call Report within 45 days of each calendar quarter end. Annual financial statements within 90 days of the fiscal year end. HMDA data by 1 March for lenders above the loan thresholds
ExemptBanks, savings associations and federally insured credit unions. Their loan officers register federally under Regulation G (12 CFR 1007) rather than holding state licences

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What is the US Mortgage Company Licence (NMLS)?

A US mortgage company licence is the permission a state gives a non-bank to broker, lend or service residential mortgage loans on homes in that state. Each state writes its own law and sets its own entry tests, so a firm that operates nationally holds a separate licence from each state regulator. Since NMLS launched in January 2008, states have moved their mortgage licensing onto it, so a company keeps one record, adds a licence request for each state, and pays state and NMLS fees in one place.

The licence sits on top of a federal floor. The SAFE Act of 2008 requires every state to license individual loan officers to the same minimum standard, and the CFPB's Regulation H sets out that standard. The federal consumer laws then apply to the licensed business: RESPA for settlement and servicing, TILA for cost disclosures and loan officer pay, ECOA for fair lending, and HMDA for loan data. Non-bank lenders and originators must also run an anti-money laundering programme under a FinCEN rule in force since 16 April 2012.

In practice the licence is a bundle: the company licence in each state, a branch licence for each office that originates loans, an individual MLO licence for every loan officer, a qualifying individual the regulator approves, and recurring filings that keep it all in good standing.

Who needs US Mortgage Company Licence (NMLS)?

Any non-bank company that arranges, makes, funds or services residential mortgage loans secured on a home in a US state, and every individual who takes a mortgage application or offers or negotiates loan terms for pay.

  • - Mortgage brokers that take applications and place loans with lenders
  • - Non-bank lenders and mortgage bankers that close loans in their own name, often funded through warehouse lines (short-term bank credit used to fund loans until they are sold)
  • - Mortgage servicers and subservicers that collect payments, manage escrow accounts and handle arrears, and firms that own servicing rights
  • - Online and fintech lenders that originate in many states from one office or with remote staff
  • - Non-US and UK groups entering the US home loan market through a US subsidiary
  • - State-licensed subsidiaries of banks, which still file the Mortgage Call Report
  • - Loan officers moving from a bank to a non-bank lender, who must move from federal registration to a state licence

The first misconception is that a licence in the home state covers the country. It does not. Each state licenses mortgage activity on homes in that state, and the Mortgage Call Report itself is broken down by the state where each property is located. The second is that only the loan officers need a licence. The company needs its own licence, and Regulation Z (12 CFR 1026.36(f)) makes the company responsible for ensuring each loan officer is licensed or registered before that person acts as a loan originator. The third is that servicing sits outside licensing. Many states license servicers separately or through an endorsement: Florida requires US$250,000 of net worth for a lender with a servicing endorsement, and New York and Pennsylvania each have a separate servicer licence or registration. A firm that buys servicing rights can need a licence even if it never originates a loan.

Broker, lender or servicer: which licence each state requires

States license three core activities. A mortgage broker takes applications and arranges loans that another lender funds. A mortgage lender, called a mortgage banker in states such as New York and Wisconsin, makes the loan in its own name and usually funds it. A mortgage servicer collects payments, runs escrow accounts and deals with borrowers in arrears, either for loans it owns or for other investors.

Each state draws the lines differently. California's Department of Financial Protection and Innovation (DFPI) issues one Residential Mortgage Lending Act licence that covers lending and servicing. Florida issues a mortgage broker licence and a mortgage lender licence, with servicing added as an endorsement. Pennsylvania has separate broker, lender and servicer licences. Texas has a mortgage company licence through its Department of Savings and Mortgage Lending.

The NMLS business activity list drives what a company reports later. First mortgage brokering, first mortgage lending and first mortgage servicing each map to a different part of the Mortgage Call Report, so the activities selected on the MU1 should match the licences held and the business actually done.

Loan officer licensing under the SAFE Act

Regulation H defines a loan originator as an individual who, for pay, takes a residential mortgage loan application and offers or negotiates loan terms, or who advertises that they can. Every such person working for a non-bank needs a state MLO licence and an NMLS unique identifier. Independent contractor loan processors and underwriters need one too.

To qualify, an individual must have at least 20 hours of NMLS-approved pre-licensing education, including 3 hours of federal law, 3 hours of ethics and 2 hours on non-traditional mortgage products. They must pass the SAFE MLO Test with at least 75%, submit fingerprints for an FBI check, authorise a credit report, and show financial responsibility, character and general fitness.

Two criminal history rules are absolute. Nobody can be licensed who has had an MLO licence revoked, or who has a felony conviction in the 7 years before applying, or at any time where the felony involved fraud, dishonesty, a breach of trust or money laundering. Each year the licence renews only if the MLO has completed 8 hours of approved continuing education.

  • - Test format: 120 questions, 115 of them scored, in 190 minutes, for US$110
  • - Retakes: 30 days after a first or second failure, 180 days after a third
  • - First-time pass rate: 53% as at 31 December 2024
  • - Test results expire after 5 consecutive years without a licence or federal registration
  • - Some states add hours: Texas requires 23 hours of pre-licensing education and New York 11 hours of annual continuing education

Qualifying individuals, control persons and branches

The company record in NMLS is the MU1 form. It lists the company's business activities, addresses, direct owners and executive officers, indirect owners and qualifying individuals. Every natural person listed files an MU2 and attests to it from their own NMLS account. The company filing is not complete until each of those individual filings has been attested.

The qualifying individual is the person the state holds responsible for the licensed business. States use different names for the role and set their own tests. Florida, for example, requires each mortgage lender to be run by a principal loan originator who is a licensed loan originator, and each branch to be run by a branch manager who is also licensed.

Each branch that conducts licensed activity needs its own MU3 filing and branch licence in each state that licenses branches, with a branch manager who files an MU2. California requires a new branch to be filed at least 10 days before it starts business at the new location.

Net worth and surety bonds: verified state examples

Net worth and bond requirements vary widely, and several states scale them with loan volume. The figures below are taken from the state regulator or statute, or from the NMLS License Requirements and Fees Chart, as at 20 October 2026. Bond amounts shown are the minimum; the state checklist sets how the bond grows with volume or branches.

State and licenceMinimum net worthSurety bond
California DFPI, Residential Mortgage Lending Act licenceUS$250,000 tangible net worth, kept at all timesUS$50,000 up to US$50 million of annual volume, US$100,000 up to US$500 million, US$200,000 above that
Florida, mortgage lenderUS$63,000, or US$250,000 with a servicing endorsementCheck the state checklist
Georgia, mortgage lenderUS$100,000US$250,000
Georgia, mortgage brokerUS$50,000US$150,000
Illinois, residential mortgage licenceUS$150,000 (audited) for lending or servicing; US$50,000 (compiled) for brokering with an in-state officeUS$25,000 minimum
New York, mortgage bankerUS$250,000Check the state checklist
Wisconsin, mortgage bankerUS$250,000US$300,000 for the main office and up to 5 branches, plus US$10,000 for each further branch
Washington, mortgage brokerNot requiredFrom US$20,000, based on prior-year Washington volume and adjusted by 31 March

Sources: California DFPI, Florida Statutes s. 494.00611, Washington DFI and the NMLS License Requirements and Fees Chart. Always confirm on the state checklist before filing.

The federal rules that apply once you are licensed

A state licence lets a company do business. Federal law then governs how it deals with borrowers. The CFPB writes the rules below, and the SAFE MLO Test examines loan officers on all of them. State examiners also review a licensee's books and records.

Law and ruleWhat it requiresWho it affects most
RESPA, Regulation X (12 CFR 1024)No fees or kickbacks for referring settlement business. Servicing rules on escrow, error notices and help for borrowers in difficultyBrokers, lenders and servicers
TILA, Regulation Z (12 CFR 1026)Loan Estimate within 3 business days of an application and Closing Disclosure at least 3 business days before closing. Loan officer pay cannot depend on loan terms. Licensing duty and NMLS IDs on loan documentsLenders and brokers
ECOA, Regulation B (12 CFR 1002)No discrimination in lending. Notify the applicant of a decision within 30 days of a completed applicationLenders and brokers
HMDA, Regulation C (12 CFR 1003)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 MarchLenders
Bank Secrecy Act, FinCEN rule (31 CFR 1029)An anti-money laundering programme and suspicious activity reports on transactions of US$5,000 or moreNon-bank lenders and originators

Regulation Z treats a servicer of 5,000 or fewer mortgage loans that it or an affiliate owns or originated as a small servicer, with lighter servicing obligations.

Annual renewal and the Mortgage Call Report

Every company, branch and MLO licence in NMLS renews in the same window: 1 November to 31 December. The company attests that its record is accurate, submits renewal requests and pays the fees: US$120 per company licence, US$25 per branch and US$35 per MLO licence in NMLS fees, plus state fees. A licence not renewed by 31 December expires, and the company loses its authority to do licensed business in that state. Some states allow reinstatement from 1 January to the end of February, usually with extra fees.

Renewal fails if the record carries open problems. NMLS lists the usual blockers: outstanding licence items, unpaid fees, unfiled changes to name, address or control persons, bond problems, regulatory holds, late or deficient call reports and sponsorship issues. Each MLO must also have completed continuing education for the year, and NMLS advises finishing it by its SMART deadline of 5 December 2026 so course providers have time to report it.

The Mortgage Call Report (MCR) is the quarterly report every state-licensed mortgage company, and every company employing state-licensed MLOs, files through NMLS. It has two parts: Residential Mortgage Loan Activity, broken down by state, and Financial Condition, at company level. Activity data is due within 45 days of each quarter end. Lenders and servicers file the Financial Condition part quarterly too, and brokers file it annually within 90 days of the year end. Form Version 7 applied from the first quarter of 2026.

Who is exempt: banks, credit unions and federally registered loan officers

NMLS separates the state and federal tracks by whether the firm takes deposits. Banks, savings associations and federally insured credit unions do not need a state mortgage company licence. They register in NMLS as institutions, and their employed loan officers register federally under the CFPB's Regulation G, with a unique identifier, instead of meeting the state education and testing requirements.

Federally registered institutions that employ only federally registered MLOs do not file the Mortgage Call Report. A state-licensed subsidiary of a federally regulated institution does. A loan officer who leaves a bank for a licensed non-bank needs a state licence, but can usually originate under temporary authority for up to 120 days while completing it, if they were registered continuously for the year before applying.

Mortgage broker vs lender vs servicer

The three licence types carry different capital, reporting and federal compliance burdens.

PointMortgage brokerMortgage lenderMortgage servicer
What it doesTakes applications and arranges loans funded by othersMakes and funds loans in its own name, then holds or sells themCollects payments, runs escrow and handles arrears
Typical net worthLower or none: Georgia US$50,000, Washington not requiredHigher: Georgia US$100,000, New York US$250,000Highest: Florida servicing endorsement US$250,000, New York servicer US$250,000
Call report Financial ConditionAnnual, within 90 days of the year endQuarterly, within 45 days of the quarter endQuarterly, within 45 days of the quarter end
Call report activity dataApplications, closed loans and MLOs by stateApplications, closed loans, MLOs, lines of credit and repurchases by stateLoans serviced by state, including subservicing and servicing rights owned
Federal focusRESPA referral fees, loan officer pay, NMLS IDsLoan Estimate and Closing Disclosure timing, ability to repay, ECOA, HMDARegulation X servicing rules, periodic statements, small servicer test of 5,000 loans

Many firms hold more than one type. A lender that keeps servicing rights usually needs a servicing licence or endorsement as well.

State application fees and loan officer fees, examples

State fees are paid through NMLS with the NMLS processing fee of US$120 per company licence and US$35 per MLO licence.

StateCompany licence application feeMLO licence state fee
California DFPIUS$1,000 (US$100 investigation and US$900 filing)US$300
FloridaLender US$500; broker US$425US$195
New YorkMortgage banker US$3,000; mortgage broker US$1,500; servicer US$3,000US$425
Texas SMLMortgage company US$325US$145, including a US$20 recovery fund fee
IllinoisResidential mortgage licence US$2,700US$200, plus a US$50 sponsorship fee
PennsylvaniaLender US$1,500; broker US$1,000; servicer US$2,500US$200
WashingtonMortgage broker US$901US$125

Source: NMLS License Requirements and Fees Chart and California DFPI, as at 20 October 2026. Regulatory Counsel's professional fee is a fixed fee set out in a written proposal.

Key requirements

A licence for each state and activity

Choose the right licence type in each state: broker, lender or servicer, or a combined licence where the state offers one. The NMLS License Requirements and Fees Chart lists every licence type, fee, net worth figure and bond amount by state.

Qualifying individual

Most states require a named individual who meets the state's experience, education or testing standard to represent the company, sometimes called the qualified person in charge or principal loan originator. Florida requires the principal loan originator and each branch manager to be licensed loan originators. Many states require advance notice before the qualifying individual changes.

Owners, officers and background checks

Every direct owner of 10% or more and every executive officer files an MU2 with personal history, disclosure answers and, where the state requires it, fingerprints and a credit report. Indirect owners up the chain must also be shown.

Net worth and financial statements

Most lender and servicer licences require a minimum net worth shown in financial statements of the type the state demands: audited, reviewed or compiled. Annual statements are then uploaded to NMLS within 90 days of the fiscal year end, or sooner where the state requires.

Surety bond

Most states require a surety bond, filed electronically in NMLS. Several scale the amount with loan volume and require it to be reset each year: California moves from US$50,000 to US$200,000, and Washington requires mortgage brokers to adjust their bond by 31 March.

Licensed and sponsored loan officers

Each loan officer needs a state MLO licence in each state where they originate, sponsored by the licensed company in NMLS. The company's name and NMLS ID, and the loan officer's, must appear on the credit application, the Loan Estimate, the Closing Disclosure, the note and the security instrument.

Branch licences

Each office that conducts licensed activity needs its own branch licence on an MU3 filing, with a named branch manager who files an MU2. NMLS allows one branch record per physical address.

Compliance programme

Written policies covering RESPA, TILA, ECOA, HMDA, privacy, advertising, complaints and an anti-money laundering programme with suspicious activity reporting for transactions of US$5,000 or more. State examiners review these policies and the records behind them after licensing.

What does a US mortgage company licence cost?

The cost has four parts: NMLS processing fees, state fees, capital and bonding, and the professional and audit work to prepare the file. NMLS fees are set by the State Regulatory Registry board and rose on 1 March 2025 for the first time since NMLS launched in 2008. Card payments carry a 2.5% service fee; ACH bank transfers do not. Net worth is the company's own capital, not a fee, but it must be held at all times. Bond premiums depend on the insurer and the company's financial strength.

ItemFeeWhen charged
Company licence (MU1)US$120 per state licenceOn application and at each annual renewal
Branch licence (MU3)US$25 per state licenceOn application and at each annual renewal
MLO licence (MU4)US$35 per state licenceOn application and at each annual renewal
MLO change of sponsorshipUS$35 per state licenceEach time a company sponsors an MLO's licence
FBI criminal background checkUS$36.25 (plus US$10 for a print card packet)Each new application, once per filing
Credit reportUS$15Each new application, unless one under 30 days old is on file
SAFE MLO TestUS$110Each attempt

The application process

1

Map activities to licences, state by state

We confirm whether the business brokers, lends, services or does all three, in which states and through which channels, and match each activity to the licence type each state requires, using the NMLS chart and each state checklist.

2

Set up the entity, owners and qualifying individual

We structure the US entity, identify every direct and indirect owner and executive officer, and select a qualifying individual who meets each target state's experience and licensing test before anything is filed.

3

Prepare financial statements, bond and policies

We work with the client's accountants on statements that show each state's net worth at the right level of assurance, arrange the bond riders by state, and draft the compliance manual, AML programme and complaint procedures.

4

File the MU1, MU2 and MU3 forms in NMLS

We build the company record, coordinate each individual's MU2 and the branch MU3 filings, pay NMLS and state fees, and send any documents the state requires outside NMLS within its deadline.

5

License the loan officers

We plan education, testing and background checks for each MLO, set up sponsorship, and use temporary authority where an experienced loan officer qualifies, so origination can start on approval.

6

Clear licence items and go live

We answer each regulator's licence items, track approvals state by state, and hand over a live compliance calendar for the Mortgage Call Report, renewals, bond resets and audited accounts.

There is no national clock: each state reviews on its own timetable. Florida, as an example of a statutory period, must flag errors within 30 days of receiving an application and approve or deny within 90 days of a complete one, and an application counts as received only once NMLS has delivered the form, background check results, credit report and fees. Preparing a clean company file, financial statements and qualifying individuals is the stage the applicant controls. Loan officer licensing runs alongside, and an experienced MLO moving from a bank or another state can originate under temporary authority for up to 120 days while the application is pending.

How long does a mortgage company licence take?

The timeline is the sum of preparation, NMLS filing, state review and loan officer licensing. Only the review stage is set by the state, and most states do not publish a fixed period. The stages below show where time is spent and who controls it.

StageWhat happensTime set by
PreparationEntity, owners and qualifying individual chosen; financial statements, bond and policies preparedThe applicant
NMLS filingMU1, MU2 and MU3 forms filed, fees paid, fingerprints and credit reports processed, state documents sentThe applicant and NMLS
State reviewLicence items issued and answered. Florida, for example, flags errors within 30 days and decides within 90 days of a complete applicationEach state
Loan officersEducation and test before applying; 30-day wait between early test attempts; temporary authority of up to 120 days for qualifying MLOsThe individual and the state
Go liveLicence shown as approved in NMLS; sponsored MLOs can originate in that stateEach state

Why applications fail, and how we prevent it

A qualifying individual who does not meet the state test

States set their own experience and licensing standards for the person in charge. A file built around someone who does not qualify in a key state stalls there. We check each target state's standard before the MU1 is filed.

Financial statements at the wrong level or of the wrong type

States specify audited, reviewed or compiled statements and a minimum net worth that must be kept at all times. We align the statements and the net worth calculation with each state before submission.

Loan officers acting before they are licensed and sponsored

An MLO who takes applications before the state licence is approved and sponsored, or outside temporary authority, exposes both the individual and the company. We sequence MLO licensing so nobody originates early.

Bonds that do not keep pace with volume

Several states scale the bond with prior-year volume. A bond that is not raised on time becomes a licence deficiency. We diarise each state's reset date, such as 31 March for Washington mortgage brokers.

Missed call reports that block renewal

A late Mortgage Call Report places a deficiency on the licence, and reporting delinquencies are one of the listed items that can prevent renewal. We run the quarterly filings and the year-end renewal as one calendar.

Out-of-date MU2 and MU4 records after the April 2026 NMLS release

NMLS changed the disclosure questions and employment history on 18 April 2026 and asked for updates by 31 August 2026. Records left incomplete can delay filings and the renewal for 2027. We audit every individual record before 1 November.

Practitioner notes

  • - Start with the qualifying individual: each state sets its own standard, and the company filing is not complete until that person's MU2 is attested
  • - Use the NMLS chart to group states by net worth and bond so the capital plan covers the hardest state from day one
  • - File the MCR for every quarter in which a licence is held, even if no loans closed
  • - Diarise bond resets by volume: California on prior-year volume, Washington mortgage brokers by 31 March
  • - Finish MLO continuing education by 5 December 2026 and clear licence items before 1 November
  • - If you also hold a UK FCA mortgage permission, align the two compliance calendars so year-end US renewals do not clash with UK returns

How we help

Licensing strategy

We map broker, lender and servicer activity to each state's licence, choose the qualifying individual and plan the rollout order across states.

NMLS applications

We prepare and file the MU1, MU2 and MU3 forms, financial statements, bonds and state documents, license the MLOs and answer every licence item.

Renewals and reporting

We run the Mortgage Call Report, the annual renewal, continuing education tracking, bond resets and federal compliance testing so every licence stays in force.

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 license mortgage brokers, lenders and servicers through NMLS alongside the money transmitter, consumer lending and UK FCA mortgage permissions many of our clients also need, so one plan covers every market. Professional fees are a fixed fee set out in a written proposal, and every enquiry is answered the same business day.

Frequently asked questions

No. Mortgage brokers, lenders and servicers that are not banks are licensed by each state where they do business, through NMLS. The SAFE Act sets a federal minimum for licensing individual loan officers, and federal consumer laws apply to the business, but the company licence itself is a state licence.

The company licence authorises the business to broker, lend or service in a state. The MLO licence authorises an individual to take applications and negotiate loan terms. A company needs both: its own licence and a licensed, sponsored MLO for every loan officer working in that state.

It depends on the state and the licence. Examples verified as at 20 October 2026: California DFPI US$250,000 tangible net worth; Florida mortgage lender US$63,000, or US$250,000 with a servicing endorsement; Georgia mortgage lender US$100,000; New York mortgage banker US$250,000. Several states require none for brokers.

Every year between 1 November and 31 December in NMLS, for company, branch and MLO licences. A licence not renewed by 31 December expires. Some states allow reinstatement from 1 January to the end of February, usually with additional fees.

Within 45 days of each calendar quarter end: 15 May, 14 August, 14 November and 14 February. Lenders and servicers file the Financial Condition section quarterly with the activity data. Brokers file the Financial Condition section once a year, within 90 days of the year end.

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. A state-licensed subsidiary of a bank is not exempt and files the Mortgage Call Report.

Only under temporary authority. An MLO employed by a state-licensed company who was federally registered for the full prior year, or licensed in another state for the prior 30 days, can originate for up to 120 days while the application is pending, unless disqualified.

On 18 April 2026 NMLS updated the disclosure questions on the MU2 and MU4 forms and began filling MLO employment history from company relationships. NMLS asked for updates by 31 August 2026 to avoid delays in the renewal for 2027. The Mortgage Call Report also moved to Form Version 7 from the first quarter of 2026.

Primary sources

The requirements, fees and timeframes on this page are taken from the following primary regulatory and legislative sources. Rules change, and firms should confirm the current position before relying on any figure.

Last reviewed by the Regulatory Counsel team on 20 October 2026.