Providing Disclosure Explanations

How to provide explanations to disclosure questions in the MU4 form and upload appropriate supporting documentation.

About this task

Users of NMLS must provide Disclosure Explanations for any Disclosure Question with a Yes response, and may provide explanations for No responses. An explanation is intended to provide regulators with additional information necessary for the proper evaluation of a license application.

An explanation can only be used to provide information for a single event (e.g., court order, regulatory action, civil settlement). If users have multiple events that require disclosure, they should complete multiple explanations.

Attention: Any Explanation and related material, once attested to and submitted, can be amended or replaced, but the original submission will always remain part of the company or individual’s historical record in NMLS. It cannot be completely removed from the company or individual record in NMLS. Please carefully review any Explanation prior to attestation and submission.
Each Explanation is comprised of the following information:
Brief Description of Explanation
A brief statement describing what event the Explanation relates to (e.g. Felony, Cease and Desist Order).
Disposition
The current status of the event for which the Explanation is being provided. You can choose from a drop down menu including the following options:
  • Pending
  • On Appeal
  • Final
  • Open
  • Closed
  • Other
If you select Other, a Disposition Description must be provided.
Event Explanation Detail (4,000 character limit)
Provide a detailed description of the event including the date. This field must be completed in order to submit an Explanation. If you chose to provide a supporting document that contains all relevant details, you will need to upload that document as a PDF (see Supporting Document below) and provide some form of an explanation in this field. The explanation provided should be specific to the event you are describing related to the disclosure question. The explanation should provide regulators with enough information regarding the event in order for them to complete their review.
Applicable Questions
Select the checkbox next to the disclosure question(s) with Yes responses related to the Explanation you have provided. A single Explanation can be associated to one or more questions and multiple Explanations can be associated to a single question.
Supporting Document
  • You may upload any applicable supporting documentation by browsing for the document on your computer.
  • Supporting documentation should include official documents that relate to an event, (i.e. court order, disposition, administrative action.)
  • Do not combine documents related to multiple events into a single Supporting Document.
  • Only a single PDF can be uploaded for an event. If you have multiple documents for a single event, you should combine them into a single PDF file.
  • A PDF file is not required by the system in order to submit an Explanation, though your regulator may subsequently require provision of some form of documentation. Examples of documents may include: Criminal or Civil Court Documents, Administrative Orders, and other public documents. Please contact your regulator if you have specific questions regarding what documents should be provided.

A separate Explanation should be provided for each event resulting in a Yes response to a disclosure question. In addition, a single Explanation can be associated to one or more disclosure questions.

Important: Once you have completed the remainder of the filing or are ready to submit be sure to do so through the Attest and Submit section.

Guidance on how to interpret each question and format explanations is available in the NMLS Policy Guide. In general, you should clearly describe the event, include dates and locations, and explain the outcome and current status.

Documents should be named clearly and uploaded in the Disclosure Explanations section of your MU4 filing. For formatting and examples of acceptable file names, see Document Upload Descriptions and Examples.

Procedure

  1. Navigate to the NMLS Login page (State Context).
  2. Log in to your NMLS account.
  3. Navigate to your MU4 Filing.
    • If you already have a license and need to make an update, select Update Record from the Actions section.
    • If you already have a filing in progress, select the MU4 Filing link under My Tasks.
    • If you are completing a new license application, select the Add New License button.
    An MU4 Form is opened.
  4. Click the Disclosure Questions link on the left navigation panel.
  5. For each question where you have indicated a Yes response, click Add Explanation.
  6. Complete all required fields.
  7. Optional: Select Browse to locate a supporting PDF document, then select Open.
  8. Click Save.
    Note: NMLS scans uploaded files for viruses. This process can take up to 10 minutes to complete. You cannot submit the filing until the virus scan is complete. If a virus is detected, remove the document and re-upload a virus-free version of the file.
  9. Repeat this process for all disclosure questions, as necessary.