What are the NMLS licensing requirements for bank-employed mortgage loan officers?

Bank-employed mortgage loan officers register federally rather than obtain a state license. Employees of covered financial institutions (generally banks and credit unions) register through the Nationwide Mortgage Licensing System (NMLS) under Regulation G and maintain a unique identifier. Registration requires no national test or pre-licensing education, but it does require fingerprints for an FBI criminal background check. New registrants must meet the same felony standards as state-licensed originators.

Bank employees do not hold state MLO licenses. If you work for a federally regulated bank or credit union, you register through the federal registry on your NMLS record instead of filing Form MU4 with the Alaska Division of Banking and Securities. If you later move to a state-licensed mortgage company, you file the MU4 with the state, and you may qualify for Temporary Authority to keep originating loans while completing any remaining state requirements.

Bank employees do not need a state loan officer license in Arkansas. Under the Fair Mortgage Lending Act, employees of state or federally chartered banks, savings institutions, and credit unions are exempt persons who register rather than license, and they register through NMLS rather than obtaining a state loan officer license from the Arkansas Securities Department.

Bank employees do not need a Connecticut state mortgage loan originator license. Individuals who work for federally insured depository institutions, such as banks and credit unions, instead register with the Nationwide Multistate Licensing System (NMLS) as federal registrants. A unique NMLS identifier is required either way, and a loan originator leaving depository employment may qualify for temporary authority to originate loans while completing state licensing requirements.

Bank-employed mortgage loan officers do not need a Delaware state license. Individuals who act as registered mortgage loan originators for depository institutions and their regulated subsidiaries, or for Farm Credit Administration institutions, are exempt from Delaware's licensing law and instead register with the Nationwide Multistate Licensing System (NMLS). If they later move to a state-licensed mortgage company, they may qualify for Temporary Authority to keep originating loans while completing state licensing requirements such as education and testing.

Bank-employed loan originators are federally registered under the SAFE Act rather than state-licensed, so they register through NMLS with their depository institution instead of obtaining the Kansas loan originator license. When such an originator moves to a state-licensed Kansas mortgage company, Temporary Authority under 12 U.S.C. 5117 permits originating loans while completing state requirements. That authority begins when the application is submitted and ends at the earliest of withdrawal, denial, license grant, or 120 days if the application is incomplete.

Loan officers employed by banks register rather than apply for a state license. A mortgage loan originator who works for a depository institution, a federally regulated subsidiary of one, or a farm credit institution is exempt from New Mexico's state MLO licensure requirements and instead registers through NMLS as a federally registered MLO. The New Mexico Financial Institutions Division does not regulate federally chartered banks, savings and loan associations, or credit unions.

Mortgage loan officers employed by federally regulated banks and credit unions do not need a state license; they register through the NMLS Federal Registry instead. The Oregon mortgage loan originator license from the Division of Financial Regulation is required for individuals who work for state-regulated non-bank mortgage companies. A federally registered loan officer who moves to a non-bank company may qualify for federal Temporary Authority to keep originating loans for up to 120 days while completing Oregon's education and testing requirements.

Bank-employed loan originators do not get a state license. Instead, they register in the federal registry through NMLS, because state licenses apply only to individuals working for state-regulated non-bank companies. If a registered originator later moves to a non-bank employer, S.2155 temporary authority lets them keep originating for up to 120 days while they complete the state's education and testing requirements.

Bank-employed loan officers register rather than apply for a state license. South Dakota exempts employees of depository institutions, their regulated subsidiaries, and Farm Credit Administration-regulated institutions from the state MLO license. They must still register and maintain a unique identifier through NMLS.