Do mortgage underwriters need a license to work?
Most mortgage underwriters do not need a license. Federal law exempts underwriters and loan processors who perform clerical or support duties at the direction of a state-licensed or registered loan originator, provided they do not offer or negotiate rates or terms or hold themselves out to the public as originators. An independent contractor who performs underwriting or processing work must be a state-licensed loan originator.
In Alabama, it depends on how the underwriter is employed. Independent-contractor loan processors and underwriters must hold a mortgage loan originator license under the Alabama SAFE Act (Code of Ala. § 5-26-4(3)). Underwriters employed by a licensed company and working under its supervision are excluded from the MLO definition, so they do not need an individual license (§ 5-26-3(5)).
Sources: Alabama Banking Dept: SAFE Mortgage Licensing Act text (PDF) — Code of Ala. Title 5, Chapter 26; Alabama Banking Dept: Alabama Mortgage Brokers Licensing Act (Code of Ala. 5-25) text (PDF).
Yes, if the underwriter works as an independent contractor. Alaska's licensing checklist states that a loan processor or underwriter who is an independent contractor must hold the Mortgage Loan Originator license. The rule is written for independent contractors, so underwriters employed directly by a licensed company are not the target of the requirement.
Sources: Alaska DBS: Mortgage Loan Originator New Application Checklist (Rev. 05/2025); Alaska DBS: Mortgage Broker/Lender New Application Checklist (Rev. 05/2025).
No, if you only underwrite loans. Arizona requires a loan originator license only for a person who, for compensation, takes a residential mortgage loan application, offers or negotiates the terms of a residential mortgage loan, or negotiates with a lender or note holder on a borrower's behalf to modify an existing loan. Underwriting alone is not one of those activities.
Sources: A.R.S. 6-991.03: Loan originator licensing; renewal; qualifications; application; fees; A.R.S. 6-991.04: Issuance of LO license; employer notice; renewal; inactive status; address change; fee.
No, unless the job includes loan officer duties. Arkansas rules classify the receipt, collection, and distribution of information used in underwriting a mortgage loan as clerical or administrative work that carries no license requirement, so long as it does not include soliciting or accepting applications or negotiating loan terms. An underwriter who performs those licensed activities for compensation from a mortgage broker or mortgage banker must hold a loan officer license.
Sources: 23 CAR 301: Rules of the Fair Mortgage Lending Act (Arkansas Securities Department).
Underwriters who are employees of a single company and do not represent to the public that they perform loan-originator activities are exempt under Colorado law, section 12-10-709, so no license is needed. An underwriter working as an independent contractor must hold a mortgage loan originator license under section 12-10-704(2).
Sources: Colorado Division of Real Estate: MLO steps for initial licensure; Colorado DRE: MLO application instruction guide (incl. temporary authority).
Yes, in Connecticut. The state requires a loan processor or underwriter license for that work, a rule that stands out among states. The license is not required when the person is an employee of a licensed lender or broker who performs processing or underwriting at the direction of and under the supervision of a licensed mortgage loan originator. Licensed processors and underwriters register with NMLS, maintain a unique identifier, and renew annually under standards that include continuing education.
Sources: Conn. Gen. Stat. Ch. 668 Part I (36a-485 to 36a-498h): mortgage lenders, brokers and loan originators; NMLS: Connecticut state-specific PE and CE requirements for MLOs.
It depends on how the underwriter is employed. A loan processor or underwriter working as an independent contractor must obtain and maintain a mortgage loan originator license from the Delaware State Bank Commissioner. An employee processor or underwriter who works at the direction and under the supervision of a licensed mortgage loan broker or licensed lender does not need a separate MLO license.
Sources: 5 Del. C. Ch. 24: Mortgage Loan Originators (Delaware SAFE Act); 5 Del. Admin. Code § 2401-5.0: Fees (Regulation 2401).
In DC, an underwriter who engages solely in underwriting activities and does not hold themselves out to the public as able to perform mortgage loan originator activities does not need a license (D.C. Code § 26-1103). Independent contractor underwriters are treated differently: D.C. Code § 26-1101(5A) defines them as individuals required to maintain an MLO license.
Sources: NMLS: District of Columbia State-Specific Education Requirements (PE and CE) for MLOs; D.C. Code § 26-1103: License Requirements.
No, not if underwriting is your only role. Georgia exempts an exclusive W-2 processor or underwriter of a licensed broker or lender from mortgage loan originator (MLO) licensing, as long as that person does not take loan applications or help borrowers negotiate terms. If you also take applications, offer or negotiate loan terms, or assist consumers in applying, you cross into MLO activity and must be licensed.
Sources: Ga. Comp. R. & Regs. 80-11-5: Mortgage loan originator licensure and other requirements; Ga. Comp. R. & Regs. 80-5-1-.02: License and supervision fees (LII mirror).
Only in some cases. Hawaii requires underwriters who act as independent contractors to be licensed as mortgage loan originators. Underwriters who are employees performing their duties under the direction and supervision of a person licensed or exempt under Chapter 454F do not need a license.
Sources: HRS 454F-22: Mortgage loan originator, MLOC, exempt sponsoring MLOC, nonprofit, and mortgage servicer company fees (DFI copy, amendments through 2014); HRS 454F-6: Pre-licensing and re-licensing; education of mortgage loan originators (DFI copy, amendments through 2014).
It depends on the work arrangement. In Idaho, a mortgage underwriter who works as an independent contractor must hold the Mortgage Loan Originator License, and the license is also required for an underwriter who is a W2 employee of an Exempt Entity Registrant. An underwriter who does not take residential loan applications or negotiate loan terms for compensation is not within the licensing requirement.
Sources: NMLS: Idaho state-specific PE and CE requirements for MLOs; Idaho DOF Guidance Statement 2020-01-CFB: financial responsibility/fitness of MLOs and key individuals.
Not by default in Illinois. The state requires the mortgage loan originator license only for an individual who, for compensation or gain, takes a residential mortgage loan application or offers or negotiates the terms of a residential mortgage loan. Underwriting alone falls outside that definition, so an underwriter needs the license only if the job also includes those activities.
Sources: Illinois IDFPR: Mortgage loan originator (official MLO licensing page); IDFPR: Mortgage Loan Originator Frequently Asked Questions.
It depends on the employer. Indiana rule 750 IAC 9 excludes loan processors and underwriters who work exclusively as employees of a licensed or exempt mortgage company from the mortgage loan originator definition, so they need no MLO license. An underwriter who is not such an employee must obtain an MLO license and unique identifier to engage in residential mortgage activities.
Sources: Indiana DFI: MLO FAQ (updated 08/26/2025); NMLS: Indiana (IN - DFI) state-specific PE and CE requirements for MLOs.
No, if the underwriter is a W-2 employee of a company licensed under Iowa's mortgage licensing chapters. Iowa Code 535D.4(2) requires an independent-contractor loan processor or underwriter to hold a mortgage loan originator license and a Nationwide Multistate Licensing System (NMLS) unique identifier, while a W-2 employee processor or underwriter does not.
Sources: Iowa Administrative Code 187—Chapter 19: Mortgage loan originators.
No, a license is not required for loan processors or underwriters who perform clerical or support duties as employees at the direction and supervision of a licensed or exempt person. The exception ends if the underwriter offers or negotiates loan rates or terms, counsels consumers about rates or terms, or represents to the public that they can perform loan originator activities.
Sources: K.S.A. 9-2203: License required; loan originator registration; one company; remote locations; K.S.A. 9-2204: Application for mortgage company license and loan originator registration.
Independent contractors working as loan processors or underwriters must be separately licensed by filing a Form MU4 through NMLS under the Louisiana S.A.F.E. Residential Mortgage Lending Act. Underwriters who only perform supervised processing work, and do not take applications or negotiate loan terms, generally do not need their own license. Any individual who takes residential mortgage loan applications, or offers or negotiates loan terms, must hold an originator license.
Sources: La. R.S. 6:1086: Licensure requirement; La. R.S. 6:1088: Application for licensure; surety bond.
Only independent-contractor underwriters need a license. Under federal rules (12 CFR 1008.103), independent-contractor loan processors and underwriters must be state-licensed unless they perform only clerical or support duties. Underwriters employed by banks and credit unions register federally through NMLS instead of holding a state license.
Sources: 9-A M.R.S. Article 13: Maine Secure and Fair Enforcement for Mortgage Licensing Act of 2009 (index); 9-A M.R.S. §13-104: State license and registration application and issuance.
No, in most cases. Maryland excludes an individual who acts solely as a mortgage loan underwriter from the mortgage loan originator definition, so no MLO license is needed. The exclusion does not cover independent-contractor underwriters. Maryland treats independent-contractor underwriting as mortgage loan originator activity, which requires an MLO license.
Sources: Md. Code Fin. Inst. §11-606: Prelicensing education; Md. Code Fin. Inst. §11-604: License application and fees.
No. Under 209 CMR 41.00, loan processors and underwriters acting as employees are exempt from mortgage loan originator licensing in Massachusetts. The exemption does not cover independent contractors. If an underwriter takes residential mortgage loan applications or offers or negotiates loan terms for compensation, the person must be licensed.
Sources: Massachusetts Division of Banks: Apply for a Mortgage Loan Originator license; 209 CMR 41.00: The Licensing of Mortgage Loan Originators (full text, Final Amendments effective 1/10/20).
No. Loan underwriting is not covered by the SAFE Act licensing requirement, so mortgage underwriters do not need an MLO license or a state certification to work in Michigan. Underwriters fall under licensing rules only if they begin taking residential mortgage loan applications or negotiating loan terms for compensation.
Sources: Michigan DIFS: Mortgage Loan Originator licensing page; Michigan DIFS: Schedule of Fees — Mortgage Loan Originator (2026).
No, as long as you act solely as an underwriter. Missouri law excludes loan processors and underwriters acting solely in that capacity from the definition of mortgage loan originator, so no license is required. If you also take residential mortgage loan applications or offer or negotiate loan terms for compensation, you must be licensed as an MLO.
Sources: RSMo 443.706: Licensure required, exemptions; RSMo 443.711: MLO application form, NMLS, fees.
No, if you work as an employee performing only clerical or ministerial tasks. Nevada excludes employee underwriters from mortgage loan originator licensing (NRS 645B.0125). Underwriters who work as independent contractors associated with a mortgage company or certificate-of-exemption holder must hold an MLO license.
Sources: NMLS: Nevada state-specific PE and CE requirements for MLOs; Nevada MLD: residential/commercial MLO FAQ.
No. New Jersey exempts loan underwriters who perform solely clerical or support duties as supervised employees from the mortgage loan originator license. The license is required only for those who take residential mortgage loan applications or offer or negotiate loan terms for compensation. An underwriter who moves into origination work must become licensed before doing so.
Sources: NJ DOBI: Mortgage Loan Originator license requirements; NJ DOBI: New Jersey-specific requirements for new MLO applicants.
Anyone who, for compensation, takes a residential mortgage loan application or offers or negotiates its terms must hold the mortgage loan originator license. New York's NMLS checklist also requires the license for independent contractor processors and underwriters (and their employees) engaged on 1-4 family New York residential property. Individuals who only take customer information and refer customers to others do not need the license.
Sources: N.Y. Banking Law § 590: Definitions; registration required; N.Y. Banking Law § 591-a: Application to register as a mortgage broker; fees.
No, as long as the individual works solely as an underwriter. North Carolina excludes loan processors and underwriters acting solely in that capacity from mortgage loan originator licensing. A company that contracts underwriting or processing services must instead register as a Mortgage Origination Support Registrant. Underwriters who also take applications or negotiate loan terms would need an MLO license.
Sources: North Carolina Commissioner of Banks: MLO licensing requirements; NCCOB: NC prelicensing education requirements.
No. Under the SAFE Act, loan underwriting is not a licensed activity; only individuals who take residential mortgage loan applications or offer or negotiate loan terms must be licensed. In Ohio, that license is the Mortgage Loan Originator License issued by the Division of Financial Institutions.
Sources: NMLS: Ohio state-specific PE and CE requirements for MLOs; Ohio Division of Financial Institutions: NMLS resources.
No, an employee who solely underwrites loans for a licensed or exempt company does not need a mortgage originator license in Pennsylvania. Underwriters who work independently and also engage in origination activities, such as taking applications or negotiating terms, must hold the license.
Sources: 7 Pa.C.S. Chapter 61: Mortgage Loan Industry Licensing and Consumer Protection (Pennsylvania Mortgage Licensing Act); NMLS: Pennsylvania State-Specific Education Requirements (PE and CE) for MLOs.
No, an underwriter who evaluates loans without performing originator activities does not need the license. Rhode Island defines a mortgage loan originator by activity: advising applicants about loan products and their terms, helping applicants complete loan applications, or negotiating or offering to negotiate a mortgage loan, all for or with the expectation of compensation. Staff whose activities are ministerial and clerical are also exempt.
Sources: NMLS: Rhode Island state-specific PE and CE requirements for MLOs; 230-RICR-40-10-2: Lenders, Loan Brokers, Small Loan Lenders, Third-Party Loan Servicers and Mortgage Loan Originators (RI DBR regulation).
No. A salaried processor or underwriter who works as an employee supervised by a licensed mortgage company is exempt from individual loan originator licensure in South Carolina. Independent-contractor processors and underwriters are treated differently: they must comply with the Licensing of Mortgage Brokers Act, though they are prohibited from originating mortgage loans.
Sources: NMLS: South Carolina (SC - BFI) state-specific PE and CE requirements for MLOs; NMLS: South Carolina (SC - DCA) state-specific PE and CE requirements for MLOs.
No. Licensure attaches to taking a residential mortgage loan application or offering or negotiating loan terms, and loan underwriting activities are not covered by those triggers. A Tennessee underwriter who does not take applications or negotiate terms therefore does not need a mortgage loan originator license. Anyone whose work crosses into those activities, for compensation or gain, must be licensed.
Sources: Tenn. Comp. R. & Regs. ch. 0180-17: Rules pertaining to mortgage lending, loan servicing and loan brokering; Tennessee Department of Financial Institutions: Mortgage Loan Originator license page.
No. An individual engaged solely as a loan processor or underwriter is excluded from Utah's loan originator definition under Utah Code 70D-3-102(12)(a), so that work alone does not require a mortgage loan originator license. Licensing applies to individuals who originate, broker, or service mortgage loans for compensation or the expectation of compensation.
Sources: Utah Admin. Code R162-2c-201: Licensing and Registration Procedures (LII mirror); Utah Admin. Code R162-2c-204: License Renewal, Reinstatement, and Reapplication (LII mirror).
It depends on how the underwriter works. Washington requires a mortgage loan originator (MLO) license for independent contractor loan processors and underwriters, and for the direct day-to-day supervisor over Washington MLOs working for a licensed Consumer Loan Company. Underwriters at federally insured depository institutions generally register with NMLS as federal registrants rather than holding a state license.
Sources: Washington DFI: Mortgage Loan Originators Licensing; Washington DFI: MLO Pre-Application Requirements (testing, education).
No, mortgage underwriters in Wisconsin do not need a mortgage loan originator license to work. Wisconsin exempts loan processors and underwriters unless they hold themselves out to the public as able to perform loan originator activities. If an underwriter takes residential loan applications or negotiates loan terms for compensation, the license is required.
Sources: Wisconsin DFI: mortgage banking fees; Coverage gaps noted during research.