Work Remote FAQs
Frequently asked questions about working remote.
Requirements
- 1. Who must complete the work remote details?
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Answer:
A company will be required to indicate, to the best of its knowledge, the work remote status for each of its MLOs.
Companies should consult state specific requirements in the State Licensing Checklist Compiler.
- 2. When must this be done?
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Answer:
Work remote status must be completed for any MLO a company employs after September 20, 2025 (the date the work remote functionality was deployed in NMLS).
Existing relationships must be updated with the remote status but are not required to be updated ahead of 2026 renewals. To prepare for 2027 renewals, companies will be directed to complete their MLO work remote status details no later than August 31, 2026.
- 3.Why does it matter where the MLO works?
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Answer:
Many state statutes have specific work location requirements for MLOs and there are also employment/human resources considerations.
- 4. Where do I go to find out which states allow work remote and if there are any special state specific requirements?
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Answer:
Whether remote work is allowed for an MLO and whether there are any requirements associated with remote work can be found on the state checklists and on the Individual tab of the Licensing and Requirement Fee Chart.
If you have a question or are in doubt, you should consult your state regulator.
- 5. Does an MLO’s home need to be licensed or registered as a branch?
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Answer:
This is dependent on state law. Once a home is licensed or registered as a branch for one state, it could be deemed a branch for other states. Consult your state regulator if you have questions.
Terms
- 6. Are the terms “work remote” and “remote work” interchangeable?
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Answer:
Yes.
- 7. What does it mean to work remotely? What activity is considered working remotely?
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Answer:
The term work remote is defined as an MLO that is conducting licensable mortgage loan origination activity at a location that is not managed by the company.
- 8. I understand that as a company, I must sponsor my MLO’s licenses. What is a supervised location and why do I have to list a supervised location for each MLO?
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Answer:
Many states require sponsorship in connection with an MLO license. Sponsorship denotes that an MLO’s licensed activities are appropriately supervised by their employer for the individual to be eligible to hold an approved active license status in a state.
For users working from a company location, the supervised location is the company or branch location that an MLO works from. In the case of an individual that is fully remote, the supervised location is an assigned location noted in the company relationship section from which the individual is supervised.
Work Remote Status
- 9. One of our MLOs is office-centric, but there are rare occasions when the MLO may have a family emergency or a sick child that necessitates their working from home. Do I need to list the MLO as hybrid?
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Answer:
No. Office-centric is defined as working primarily from a licensed company or branch location. Rare occasions that necessitate remote work would not contradict the office-centric status.
- 10. Isn’t it safer to just say all my licensees are hybrid?
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Answer:
While this may seem like a safe option, the status reported must be accurate. There are also some states that do not allow work remote. See the state-specific checklist for details.
- 11. If I list an MLO’s work remote status as hybrid, does that mean the MLO works remote and in an office for all their licenses?
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Answer:
Not necessarily. If an MLO is hybrid the company will be required to indicate for which licenses the MLO works remote (“License Association”). It is understood for any license not chosen during the license association process, the MLO is office-centric.
- 12. Do I list an MLO’s status as hybrid if there are some states for which they only conduct origination activity in an office?
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Answer:
Yes. See question 15 for more information.
- 13. What do I do if the MLO is fully remote in the summer and office-centric the rest of the year?
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Answer:
In this instance it is suggested the MLO work status be Hybrid.
- 14. Will an MLO’s work remote status appear on Consumer Access?
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Answer:
No
License Association
- 15. What’s a License Association?
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Answer:
If an MLO is fully remote or hybrid, the company must indicate which licenses the MLO conducts licensed activity remotely by selecting the appropriate licenses in the License Association drop-down.
- 16. I am fully remote, do I still have to list the licenses for which I work remote?
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Answer:
Yes. This serves to affirm that the MLO works remotely for all the licenses the MLO holds.
- 17. How will a state know if a hybrid or fully remote MLO designates their state as work remote?
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Answer:
If an MLO’s work remote status is either hybrid or fully remote the company will have to indicate which license(s) the MLO works remotely. MLO licenses NOT chosen will be interpreted to mean the work status for that specific license is office-centric.
- 18. Will state regulators see all of an MLO’s license associations or just the license association of the state the regulator is in?
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Answer:
Yes. State regulators will see all the MLO’s license associations.
Miscellaneous
- 19. If an MLO is fully remote will their home address appear on Consumer Access?
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Answer:
No
- 20. If I have an MLO that works from more than one location, can I designate which location is the supervised location?
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Answer:
No. System functionality does not allow for this.
- 21. What do I do if a state considers an MLO’s work remote location to be a branch location?
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Answer:
The location will need to be licensed or registered as a branch. See question 5 for additional requirements.
Updates to Required Information
- 22. How often do I have to update work remote status?
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Answer:
A company needs to update the work remote status for an MLO as soon as practicable after it changes or if the MLO obtains a new license.
Companies should consult state specific requirements for any change notice deadlines.
- 23. What happens if an MLO moves and/or changes locations?
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Answer:
The company needs to update the MLO’s work location as soon as possible. If the MLO changes their residence, which is their work remote location, they must update their record as soon as possible.
Companies should consult state specific requirements for any change notice deadlines.
- 24. What happens if I don’t update my work remote status?
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Answer:
A regulator may post a license item or take other action against the MLO’s license.
- 25. Can a regulator reject or take action against my work remote status or location?
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Answer:
Yes. If a company sets an MLO’s work location status to something that does not conform to an agency’s licensing requirements, the regulator may initiate an action.