Can an MLO also be a real estate agent?

Yes. Federal law treats the two roles separately: the SAFE Act governs loan origination, while real estate brokerage is licensed under state law, and nothing in federal law prevents one person from holding both. An agent who performs only brokerage activity is exempt from MLO licensing unless the agent is compensated by a lender, mortgage broker, or other loan originator, in which case MLO licensing applies.

Yes. The Alabama SAFE Act does not prohibit a mortgage loan originator from also holding a real estate license, and the Alabama Real Estate Commission assesses dual loan-officer and real estate agent roles case-by-case. Anyone originating residential mortgage loans must still maintain the MLO license and show their NMLS unique identifier on loan applications, solicitations, and advertisements.

Yes. Missouri does not prohibit holding a real estate license and a mortgage loan originator license at the same time. A licensed real estate broker who performs only brokerage activity is not acting as an MLO. However, anyone compensated by a lender, broker, or loan originator for negotiating loan terms must be licensed as an MLO.

Yes. A Montana MLO may also hold a real estate brokerage license. Montana law exempts real estate brokerage licensees from MLO licensing only if they are not compensated by a mortgage broker, mortgage lender, or MLO, so a dual-role agent who receives such compensation must hold the MLO license. An MLO may also transact business for only one employing licensed broker or lender at a time.

Yes. Nebraska regulates the two roles separately: the Department of Banking and Finance licenses mortgage loan originators, while the Nebraska Real Estate Commission licenses real estate brokers and salespersons. A real estate broker or salesperson is exempt from the Residential Mortgage Licensing Act when acting only in that capacity. The exemption ends if the person is compensated by a lender, mortgage broker, or mortgage loan originator.

Yes. Nevada law treats the two licenses separately, and nothing in the state's mortgage rules prevents a mortgage loan originator from also holding a real estate license. The MLO rules do limit associations: an MLO may work for only one licensed mortgage company at a time. A real estate broker who is compensated by a lender or mortgage company for originating loans must hold the MLO license; brokers doing only brokerage activity are exempt.

Yes. New Hampshire law (RSA chapter 397-A) does not prohibit an individual from serving as both a mortgage loan originator and a real estate agent on the same transaction. Ethical standards may require the originator to provide written disclosure and obtain the client's prior written consent before acting in both roles.

Yes. New Mexico excludes persons performing only licensed real estate brokerage activities from its mortgage loan originator definition, unless they are compensated by a lender, mortgage loan company, or another MLO. If you take residential loan applications or negotiate loan terms for compensation, you must hold the MLO license even while working as an agent. Note also that mortgage brokers cannot arrange FHA loans on transactions where they act as the real estate agent.

Yes. Federal guidance issued in December 2022 permits an individual to serve as both the real estate agent and the mortgage loan originator on FHA-insured sales, and dual licensing is also permitted on conventional and VA mortgages. In New York, the originator side still requires a Mortgage Loan Originator license from the Department of Financial Services and sponsorship by a licensed mortgage banker or registered mortgage broker.

North Dakota does not allow one person to act as both the real estate agent and the mortgage loan originator on the same transaction. Owning or working in both types of businesses is not prohibited, so you may hold both credentials, but you cannot serve in both roles on a single deal.