Do you need a license to become a mortgage underwriter?
It depends on the work arrangement. A supervised loan processor or underwriter who performs clerical or support duties at the direction of a state-licensed or registered loan originator, and who does not hold themselves out to the public, does not need a state license. An independent contractor performing loan processor or underwriter activities for residential mortgage loans must be a state-licensed loan originator.
It depends on the employment arrangement. Under Alabama's SAFE Act, an independent-contractor loan processor or underwriter must obtain a mortgage loan originator license, which requires 20 hours of NMLS-approved pre-licensing education, a passing SAFE test score, and an MU4 filing through NMLS. A loan processor or underwriter who works as a supervised employee is excluded from the MLO definition and does not need the individual license.
Sources: Alabama Banking Dept: SAFE Mortgage Licensing Act text (PDF) — Code of Ala. Title 5, Chapter 26.
Yes, if you work as an independent contractor. Alaska requires a loan underwriter who is an independent contractor to hold the mortgage loan originator license, the same license any originator needs. The path is the same: 20 hours of NMLS-approved pre-licensure education, the National Test Component with Uniform State Content, a credit report and FBI background check, and sponsorship from an Alaska-licensed Mortgage Broker/Lender.
Sources: NMLS: Alaska state-specific PE and CE requirements for MLOs (MLO Testing Handbook).
Arizona does not issue a separate underwriter license. A loan originator license from the Arizona Department of Insurance and Financial Institutions (DIFI) is required only for people who take residential mortgage loan applications, offer or negotiate loan terms, or negotiate a modification with a lender on a borrower's behalf. If your underwriting work does not include those activities, you do not need the loan originator license.
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.
An underwriter does not need an Arkansas loan officer license unless the role includes licensed activity. Arkansas rules treat the receipt, collection, and distribution of information used in underwriting a mortgage loan as administrative work that carries no license requirement, as long as it does not include soliciting or accepting applications or negotiating loan terms or conditions. Performing those activities for compensation from a mortgage broker or mortgage banker triggers the license requirement.
Sources: 23 CAR 301: Rules of the Fair Mortgage Lending Act (Arkansas Securities Department).
It depends on how you work. A loan underwriter who is an employee, and who does not represent to the public that they perform mortgage loan originator activities, is exempt from licensure under section 12-10-709, Colorado Revised Statutes. An independent contractor (1099) underwriter is different: under section 12-10-704(2), an independent contractor may not perform loan origination activities as an underwriter unless the contractor holds a state mortgage loan originator license.
Sources: Colorado Division of Real Estate: MLO steps for initial licensure; Colorado DRE: MLO application instruction guide (incl. temporary authority).
Yes, in most cases. Connecticut requires a separate loan processor or underwriter license under Section 36a-489 for individuals who perform processing or underwriting for compensation. The exception is employees of a licensed lender or broker who process or underwrite loans at the direction of, and under the supervision of, a licensed mortgage loan originator; they are exempt. All licensed processors and underwriters must register with NMLS and maintain a valid unique identifier.
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 you work. A loan processor or underwriter who is an independent contractor must obtain and maintain an MLO license under Delaware law. An employee processor or underwriter who works at the direction and under the supervision of a licensed lender or mortgage loan broker (Title 5 Chapter 21 or 22 licensee) does not need an individual MLO license.
Sources: 5 Del. C. Ch. 24: Mortgage Loan Originators (Delaware SAFE Act); 5 Del. Admin. Code § 2401-5.0: Fees (Regulation 2401).
It depends on how you work. An individual who engages solely in loan processing or underwriting and does not hold themselves out to the public as able to perform loan originator activities is exempt from licensure. However, DC law treats independent contractor loan processors and underwriters as individuals who must maintain an MLO license (D.C. Code § 26-1101(5A)). So employee underwriters are generally exempt, while independent contractor underwriters must be licensed.
Sources: NMLS: District of Columbia State-Specific Education Requirements (PE and CE) for MLOs; D.C. Code § 26-1103: License Requirements.
No, not in most cases. The Georgia Department of Banking and Finance does not require a mortgage loan originator (MLO) license for an exclusive W-2 processor or underwriter of a licensed broker or lender who does not assist borrowers in applying for or negotiating loans. If you take residential loan applications, offer or negotiate loan terms, or assist consumers in obtaining loans, you must be licensed as an MLO.
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 some underwriters do. All underwriters who act as independent contractors must be licensed as mortgage loan originators under Hawaii Chapter 454F. An employee underwriter who performs duties at the direction and supervision of a person licensed or exempt under the chapter does 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 your employment structure. In Idaho, a loan processor or underwriter must hold a Mortgage Loan Originator License if working as an independent contractor, or as a W-2 employee of an Exempt Entity Registrant. An independent contractor processor or underwriter not engaged in origination activities is sponsored by that Exempt Entity Registrant.
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.
It depends on how you work. Indiana's rule excludes loan processors and underwriters who work exclusively as employees of a licensed or exempt mortgage company, so they do not need an MLO license. An underwriter who is not an employee of a licensed or exempt person must obtain an MLO license and a 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.
Only sometimes. A mortgage underwriter who is a W-2 employee of a licensed company does not need a mortgage loan originator license in Iowa. An underwriter working as an independent contractor must obtain the license and a Nationwide Multistate Licensing System (NMLS) unique identifier. Independent-contractor underwriters must meet all standard licensing requirements except the employer-affiliation rule, and they must satisfy the surety bond requirement before the license is issued.
Sources: Iowa Administrative Code 187—Chapter 19: Mortgage loan originators.
No, not if you stay within support duties. Kansas does not require the mortgage loan originator license for underwriters performing clerical or support duties as employees at the direction and supervision of a licensed or exempt person. You lose that exemption if you offer or negotiate loan rates or terms, counsel consumers about rates or terms, or represent to the public that you 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.
It depends on your employment arrangement. In Louisiana, an underwriter who works as an independent contractor must be separately licensed by filing Form MU4 through the Nationwide Multistate Licensing System (NMLS), which means meeting the education, testing, background check, and surety bond requirements. An underwriter employed by a licensed mortgage company generally works under that company's own authority instead.
Sources: La. R.S. 6:1086: Licensure requirement; La. R.S. 6:1088: Application for licensure; surety bond.
It depends on how you work. Federal rule 12 CFR 1008.103 requires independent-contract loan underwriters to hold a state mortgage loan originator license unless they perform only clerical or support duties. Underwriters employed by a federally regulated bank or credit union register through NMLS instead of holding a state license. In Maine, an independent-contract underwriter must obtain an MLO license from the BCCP.
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, if you act solely as an underwriter for a lender. Maryland law excludes individuals who act solely as mortgage loan processors or underwriters from the mortgage loan originator (MLO) licensing requirement. However, Maryland treats independent-contractor processing and underwriting as MLO activity, so an underwriter working as an independent contractor must hold an MLO license.
Sources: Md. Code Fin. Inst. §11-606: Prelicensing education; Md. Code Fin. Inst. §11-604: License application and fees.
No, a mortgage underwriter does not need a Massachusetts Mortgage Loan Originator license as long as they act as an employee. Massachusetts law (209 CMR 41.00) exempts loan processors and underwriters working as employees from MLO licensing. The exemption does not cover independent contractors, so an underwriter who contracts independently must meet the standard MLO licensing requirements if performing licensed activity.
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 underwriters do not need a mortgage loan originator license. An MLO license is required only for individuals who take residential mortgage loan applications or offer or negotiate loan terms for compensation.
Sources: Michigan DIFS: Mortgage Loan Originator licensing page; Michigan DIFS: Schedule of Fees — Mortgage Loan Originator (2026).
No, you do not need a mortgage loan originator license to work as an underwriter in Missouri. State law excludes loan processors and underwriters acting solely in that capacity from the definition of a mortgage loan originator. A license is required only if you take residential mortgage loan applications or offer or negotiate loan terms for compensation.
Sources: RSMo 443.706: Licensure required, exemptions; RSMo 443.711: MLO application form, NMLS, fees.
In Nevada, it depends on how you work. Loan processors and underwriters who are employees performing only clerical or ministerial tasks are exempt from licensure. If you work as an independent contractor associated with a mortgage company or a certificate-of-exemption holder, you must hold a mortgage loan originator license under NRS 645B.0125.
Sources: NMLS: Nevada state-specific PE and CE requirements for MLOs; Nevada MLD: residential/commercial MLO FAQ.
No, as long as you perform solely clerical or support duties as a supervised employee. New Jersey exempts loan processors and underwriters in that role from the Mortgage Loan Originator license. If you take residential mortgage loan applications or offer or negotiate loan terms for compensation, you must be licensed as a Mortgage Loan Originator.
Sources: NJ DOBI: Mortgage Loan Originator license requirements; NJ DOBI: New Jersey-specific requirements for new MLO applicants.
Only in some cases. New York requires independent-contractor underwriters and processors engaged on 1-4 family residential property to hold a Mortgage Loan Originator license. The license is also required for anyone who, for compensation, takes a residential mortgage loan application or offers or negotiates loan terms. People who only take customer information and refer it 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, you do not need a mortgage loan originator license as long as you act solely as an underwriter. The NC SAFE Act excludes individuals who only process or underwrite loans from MLO licensure. However, a company that provides contract underwriting services must register as a mortgage origination support registrant, with fees ranging from $250 to $2,000 depending on processor and underwriter headcount.
Sources: NCCOB: Mortgage fee schedule (Rev. 10/01/2025).
No. Loan underwriting is not a covered activity under the SAFE Act, so Ohio does not require a mortgage loan originator license for underwriters. A license is required for individuals who, for compensation or gain, take or offer to take residential mortgage loan applications, assist buyers in obtaining a residential mortgage loan, or offer or negotiate the terms of one.
Sources: NMLS: Ohio state-specific PE and CE requirements for MLOs; Ohio Division of Financial Institutions: NMLS resources.
No, not if you solely underwrite loans as an employee of a licensed or exempt mortgage company, because Pennsylvania law excludes those individuals from the definition of a mortgage originator. Independent underwriters who also perform origination activities, such as taking applications or negotiating loan terms, must hold a Mortgage Originator 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, provided the role stays within underwriting. Rhode Island requires the mortgage loan originator license only for people who, for compensation, advise applicants about loan products, help complete loan applications, or negotiate mortgage loans. Activities that are ministerial and clerical are exempt, so underwriting that does not involve those originating duties does not require the license.
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).
It depends on how you are employed. Underwriters who work as supervised employees of a licensed mortgage company are exempt from loan originator licensure in South Carolina. Independent-contractor underwriters must be licensed per rule and comply with the Licensing of Mortgage Brokers Act, and they must not originate 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. Under the SAFE Act, a license is required only for individuals who take residential mortgage loan applications or offer or negotiate loan terms. Loan underwriting activities are not covered, so a Tennessee underwriter performing only underwriting duties does not need a mortgage loan originator license.
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, not for underwriting alone. Utah's loan originator definition under Utah Code 70D-3-102(12)(a) does not include an individual engaged solely as a loan processor or underwriter. A license is required only for individuals who, for compensation, solicit or render services related to originating residential mortgage loans.
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 you work. In Washington, a mortgage loan originator (MLO) license is required for individuals who work as an independent contractor loan processor or underwriter representing a licensed or exempt mortgage broker or consumer loan company. The license is also required for the direct day-to-day supervisor over Washington MLOs at a licensed consumer loan company.
Sources: Washington DFI: Mortgage Loan Originators Licensing; Washington DFI: MLO Pre-Application Requirements (testing, education).
Not in most cases. Wisconsin exempts loan processors and underwriters from the mortgage loan originator license, as long as they do not hold themselves out to the public as able to perform loan originator activities. An underwriter who takes residential mortgage loan applications or offers or negotiates loan terms for compensation does need the license.
Sources: Wisconsin DFI: mortgage banking fees; Coverage gaps noted during research.