MBA's Mortgage Loan Officer Licensing Resource Center

In 2008 the Secure and Fair Enforcement for Mortgage Licensing Act (SAFE Act) established mandatory registration for all mortgage loan originators (MLOs) and also licensing for non-bank lenders, their branches and MLOs through the Nationwide Mortgage Licensing System and Registry (NMLS). Since then, there has been a national discussion about the need to address the challenges faced by licensed MLOs moving from one state to another or experienced federally registered MLOs wishing to change positions and work for a state licensed company. Such transitions often take up to three months or even longer.

The Mortgage Bankers Association (MBA) has been at the center of this dialogue among state and federal regulators, state and local mortgage banking/lending associations, and leaders within the real estate finance industry. That leadership led to the enactment of a new MLO temporary authority law for MLOs as part of S. 2155 - The Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018. New law provides for a 120-day temporary transitional authority period for bank MLOs moving to a non-bank lender, or licensed MLOs already working for a non-bank lender and wishing to work in another state or looking to obtain one or more additional state licenses. The law mandates that states implement transitional authority by November 24, 2019, i.e. 18 months after enactment. To support speedy enactment of the new law, MBA is urging the Bureau to recind its 2012 guidance on transitional authority, which no longer reflects current federal law, and reissue written guidance for the benefit of state regulators and industry alike.

The purpose of this resource center is to provide access to appropriate documents and information related to MLO licensing, with focus on implementing the new law. 

Key Resources:

Section 106 of S. 2155 on MLO Temporary Authority

MBA Issue Brief: SAFE Act: Implementation of MLO Transitional Authority

Secure and Fair Enforcement for Mortgage Licensing (SAFE) Act of 2008

NMLS Resource Center: State Licensing Requirements

Transitional Licensing Laws: New Hampshire, New JerseyNorth Carolina, Ohio, South Carolina, & Virginia 

Transitional Licensing Regulations: Colorado & New Mexico

MBA's Model Transitional Licensing Bill Amendment



100% Adoption


Latest Developments:


August 27, 2018: New Jersey enacts a 120-day mortgage loan originator transitional licensing law (A.2035A)

May 24, 2018: President signs S.2155 (Public Law No: 115-174), which in Section 106 amends the federal SAFE Act to provide a 120-day transitional authority for MLOs after an 18-month implementation period.

May 2, 2018: The Minnesota Department of Commerce will adopt the National State MLO Test with Uniform State Content (UST), effective August 1, 2018.

April 4 2018: The West Virginia Division of Financial Institutions will adopt the National State MLO Test with Uniform State Content (UST), effective June 1, 2018.

May 25. 2017: The South Carolina Departments of Consumer Affairs (SC-DCA) and the Board of Financial Institutions (SC-BFI) announced UST adoption

March 31. 2017: The Utah Division of Real Estate adopted the Uniform State Test effective May 8, 2017. 

November 22, 2016: Arkansas Securities Department Announces its Adoption of the Uniform State Test, with January 2017 Implementation

August 15, 2016: Florida OFR Announces its Adoption of the Uniform State Test, with January 2017 Implementation

May 4, 2016: Illinois DFPR Announces its Adoption of the Uniform State Test, with June 2016 Implementation 

April 28, 2016: MBA Submits Letter to Minnesota House Civil Law and Data Practices Committee Urging Support for Uniform State Test Legislation, HF 3695

March 23, 2016: MBA Submits Letter to Minnesota Senate Commerce Committee Urging Support for Uniform State Test Legislation, SF 2876

March 17, 2016: Minnesota Senator Dahle Introduces SF 2876, Legislation to Allow for Adoption of Uniform State Test by Minnesota DOC 

March 1, 2016: Utah-Headquartered Mortgage Companies Jointly Urge (View Letters Here and Here) Utah DRE to Adopt Uniform State Test

December 1, 2015: Colorado's DRE Announces its Adoption of the Uniform State Test, with March 2016 Implementation

November 24, 2015: Colorado Attorney General's Office Issues General Opinion Approving Regulations that Allow Colorado DRE to Adopt the Uniform State Test

October 16, 2015: Missouri's Division of Finance Announces its Uniform State Test Adoption, with January 2016 Implementation

July 15, 2015: California's DBO and BRE Jointly Announce their Uniform State Test Adoption, with January 2016 Implementation

May 1, 2015: Arizona's DFI Announces its Adoption of the Uniform State Test, with July 2015 Implementation

April 29, 2015: Bipartisan Legislation to Enact Transitional Licensing, H.R. 2121, Introduced in House of Representatives

March 30, 2015: Arizona Governor Signs SB 2169 into Law, Allowing for Adoption of Uniform State Test by Arizona DFI

October 2, 2014: Oregon's DFCS Announces its Adoption of the Uniform State Test, with January 2015 Implementation

July 23, 2014: Connecticut's DOB Announces its Adoption of the Uniform State Test, with October 2014 Implementation

July 10, 2014: California Governor Signs SB 1459 into Law, Allowing for Adoption of Uniform State Test by State Regulators

July 2, 2014: Oklahoma's DCC Announces its Adoption of the Uniform State Test, with October 2014 Implementation

June 26, 2014:
Ohio's DFI Announces its Adoption of the Uniform State Test, with September 2014 Implementation 

June 5, 2014:
New York State Adopts Uniform State Test and a Form of Transitional Licensing, Among other MLO Licensing Changes

March 24, 2014: Transitional Licensing Becomes Law in Virginia for State-Regulated MLOs

January 1, 2014:
Two Additional State Agencies, the Virgin Islands and Puerto Rico Implement UST

October 1, 2013: Four Additional State Agencies and the District of Columbia Implement UST

July 23, 2013: Transitional Licensing Becomes Law in North Carolina for State-Regulated MLOs

July 1, 2013: Ten Additional State Agencies Implement UST

May 20, 2013: CFPB Greenlights State Use of Uniform State Test

April 1, 2013: Twenty State Agencies Implement UST, "Standalone UST" Also Introduced

March 15, 2013: CSBS Presentation to MBA on UST Implementation Updates

January 16, 2013: CSBS Press Release, "New SAFE MLO Test with Uniform State Component to Start April 1"

December 19, 2012: Ohio SB 333 is Signed into Law by Gov. Kasich

December 4, 2012: Ohio SB 333 Passes Ohio House of Representatives

August 16, 2012: MBA Presentation on Reciprocity to the American Association of Residential Mortgage Regulators (AARMR)

August 7, 2012: NMLS Issue Brief : Responses to Transitional Licensing for Mortgage Originators

May 22, 2012: Ohio SB 333 Passes Ohio Senate

May 9, 2012: CFPB Releases Rulemaking Addressing Loan Officer Compensation and Other Aspects of the SAFE Act; please click here for the press release, or here for the full language of the rulemaking

May 9, 2012: MBA writes letter to Ohio legislative committee considering Ohio SB 333

April 24, 2012: Ohio Senator Obhoff introduces SB 333, which contains transitional licensing language

April 19, 2012: The Consumer Financial Protection Bureau (CFPB) releases bulletin addressing SAFE Act language

March 20, 2012: MBA President and CEO Dave Stevens writes letter to CFPB Director Richard Cordray urging his support for transitional licensing

March 1, 2012: Senator Sherrod Brown writes letter to CFPB Director Richard Cordray urging his support for transitional licensing

February 16, 2012: Chairman Spencer Bachus writes letter to CFPB Director Richard Cordray urging his support for transitional licensing

January 18, 2012: MBA President and CEO David H. Stevens includes need for transitional licensing in public speech at the Exchequer Club; please click here for the press release

August 29, 2011: MBA proposes transitional licensing language at American Association of Residential Mortgage Regulators (AARMR) Conference

August 4, 2011: MBA hosts conference call with the Conference of State Bank Supervisors addressing transitional licensing

July 13, 2011: Henry V. Cunningham, Jr., CMB, testifies before the House Subcommittee on Insurance, Housing, and Community Opportunity, representing MBA and its support for transitional licensing