Appendix 6: Employment Reporting FAQ

Answers to questions about the Employment History section in NMLS.

How does employment reporting work in NMLS?

Company Relationship information entered by the company automatically populates the Employment History section of all individual forms (MU4, MU2 and MU4R). This will avoid duplicate data entry, conflicting employment records and confusion over who is responsible for updating employment information.

I have to account for ten years of employment without gaps, but I had a gap. What do I do?

There is a drop down labeled “Employment Gap” which can be sued in this instance. to fill periods of the 10 year employment history requirement.

What is the best practice when managing employment history for MU4 individuals?

The best practice for MU 4 filings is to follow this process so that employment information flows automatically into the MU4:
  1. The company requests access to the MLO’s record in NMLS.
  2. The MLO accepts the request.
  3. The company creates and completes a Company Relationship
  4. The company or the MLO completes the MU4 Form. Beginning April 18, 2026, , the MU4 will automatically populate with the current employment information because the employment details were entered when the relationship was created.
  5. The MU4 is submitted and attested to, confirming the accuracy of the employment information, as well as all other information on the MU4 form.

What is the best practice when managing employment history for MU2 individuals (e.g., direct and indirect owners, branch managers, qualified individuals)?

The best practice for MU2 filings is to follow this process, which does not require a relationship to be created:
  1. The company requests access to the MU2 Individual’s record in NMLS.
  2. The MU2 Individual accepts the request.
  3. The company completes the MU2 filing for the individual. There will be no relationship details from the company in the employment history section.
  4. The MU2 is submitted and attested to
Note: It is not recommended to create a Company Relationship for individuals who are not seeking license sponsorship through an MU4 filing. If the company employs the individual, this should be reported on the MU2 using “self-entered” employment entry.

What are the different statuses for each employment entry, and what do they mean?

The Employment table shows the status of each employment entry to indicate who provided the information and whether it has been confirmed.

Status type:
Self-reported
The individual entered the employment information, and it is not associated with an NMLS Company Relationship.
Federal Employment
The employment reflects federal employment as reported on the MU4R Form in the NMLS Federal Registry. The employment information is managed through the MU4R Form (federal) and cannot be edited on the MU4 Form (state).
Pending Form Submission
The Company Relationship employment has been created, but the associated MU4 Form has not yet been submitted. The employment information cannot be changed by the individual. Changes must be made by the Company when altering the Company Relationship.
Verified
The employment information is supported by an active Company Relationship and has been attested to by the individual. The employment information cannot be changed by the individual. Changes must be made by altering the Company Relationship.

What should happen for MU2 individuals who have an existing Company Relationship?

If a Company Relationship was created for an MU2 individual who is not an employee, the relationship will still display as an employment record on the MU2 Employment History. A company may use the Position/Title field in the relationship to clarify that this individual is not an employee.

Note: In this situation, do not end the relationship, as ending the relationship will also end the MU2 association with the company.

When an ACN address change occurs, will it create a new address record or overwrite the existing address?

If something changes on the company’s MU1 or MU3, such as a company name or address change, it may affect the employment record. When this happens, the update will automatically flow to the MU4 and update the current employment record. The MLO will receive a License Item prompting them to review and resubmit their filing so the update is recorded in the filing history. No additional updates are required from the MLO beyond reviewing the information and resubmitting the filing.

If an MLO changes their title, should the relationship be ended and a new one created, or should the change overwrite the existing employment record?

A relationship is intended to cover the entire period of employment for an individual. Updates to the Position/Title field should be made to the relationship record which overwrites the existing employment history record.

Where is MLO contact information managed?

The Company Relationship will contain the below data points managed by the company:
  • Relationship Effective Date*1
  • Position/Title*1
  • Worker Classification (W2 Employee or Non-W2 Employee)*1
  • Individual’s Work Phone*1
  • Extension
  • Individual’s Work Email*1
  • Remote Work Status*1
  • Is the individual’s remove work location their current residence? (Yes or No)*1
  • Remote Work License Associations
  • Location(s)*1

These fields allow regulators to reach the MLO as soon as the relationship is created, without needing to wait for the MU4 to be revised.

1 *indicates a required field