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Your MLO: Licensed or Registered?

The SAFE Act was put in place back in 2008 to help create a national standard for residential Mortgage Loan Originators (MLO). Part of that was to create the National Mortgage Licensing System (NMLS) and to establish basis for what it takes to be a Licensed Mortgage Loan Originator. You’ll see, however, that there are two standards, and they’re not equal.

This amazing and necessary plan came about on the heals of the sub-prime mortgage meltdown, where banks and companies were imploding by the day. This was four years into my mortgage career.

The Loophole

As with any good regulation, there’s a loophole.

You’re going to love this: If a mortgage originator works for a depository institution that’s regulated by the FDIC, you know, your local bank or the big banks we all know, they are excluded from licensing. Mortgage loan originators working for FDIC (Federal Deposit Insurance Corporation) insured banks only have to be Registered with the NMLS, not Licensed. In case you’re wondering, there is a huge difference.

In Wisconsin, per the SAFE Act, a Licensed Mortgage Loan Originator must:

  • Submit fingerprints for a state and federal background check and pass both
  • Submit personal employment history and experience
  • Have a unique identifier number
  • Demonstrate financial responsibility (Personal credit is checked for bankruptcies, foreclosures, financial mismanagement etc.; the presence of which precludes a person from getting licensed)
  • Attend 20 hours of approved pre-licensing education
  • Successfully pass the state and national mortgage exam by 75% or better
  • Take 8 hours of continuing education annually, plus pass a test at the end
  • Never have had a license revoked

A Registered Mortgage Loan Originator [not Licensed] per the SAFE Act, are required to:

  • Submit fingerprints for a state and federal background check
  • Submit their personal employment history and experience
  • Have a unique identifier number
  • That’s it…no proof of proficiency in the regulations or financial responsibility needed.

Typically, a Registered MLO will tell consumers that they don’t need to do all the measures that a Licensed MLO does because it’s “in house” (ask them and listen to their response). That, of course, doesn’t make much sense.

Mortgage Banks, like the company I work for, are still banks. We just don’t do depository accounts, so we’re not regulated by the FDIC. Sometimes Mortgage Banks are cited as the need for licensure – as the cause of the meltdown – but that’s simply not true. It’s much more complicated than that. In fact, The Big Short, a movie, does a great job explaining how this all came to fruition.

You can look up your loan officer’s credentials at:

Here are mine as of 3/3/2017:

Michael Creed's, A Licensed Mortgage Loan Originator, NMLS Data

You can click the image to see a larger image or visit and either enter my name and or my NMLS LICENSE Number: 50441 in the search box.

Towards the bottom of the NMLS Consumer Access site, you can see if your mortgage originator is licensed and which states they are currently licensed to originate mortgages in. If the mortgage originator is not licensed and is only required to be registered, it will say: “Federal Mortgage Loan Originator”.

I encourage you to do your own research on mortgage originators before you start working with them.

Who would you rather have help you with what is likely the biggest transaction of your life? A Licensed MLO – with a license they must personally obtain and maintain with ongoing training? Or a Registered MLO – someone who is simply registered as noted above?

Contact me, let’s do this.

Markets in a Minute | February 3, 2017

For the Week Ending February 3, 2017
Please enjoy this quick update on what happened this week in the housing and financial markets.
The Fed concluded the most recent FOMC meeting and announced there would be no policy rate increases. The next FOMC meeting is scheduled for March 14/15.
Economic activity in manufacturing expanded in January, surpassing economists’ expectations. Manufacturers grew at the fastest pace in more than 2 years.
The Consumer Confidence Index dropped in January after reaching a 15-year high in December. Despite the slight drop, consumers remain confident overall.
Construction spending was down slightly overall in December. However, spending on residential structures was up 0.5%.
Despite an increase in mortgage rates, pending home sales rose 1.6% in December compared to November. Sales were up 0.3% year-over-year.
Home prices continue to rise, up 5.6% in November according to Case-Shiller. Increases are supported by rising personal income & decreasing unemployment.


When an employment application asks who is to be notified in case of emergency, I always write, “A very good doctor.”


Rate movements and volatility are based on published, aggregate national averages and measured from the previous to the most recent midweek daily reporting period. These rate trends can differ from our own and are subject to change at any time.