Education FAQ - Miscellaneous

Q. How does NMLS know what the education requirements are for each agency?

A. NMLS is programmed with Federal PE and CE requirements as required by the SAFE Act. State-specific PE and CE requirements are set by each state agency through a license setting interface based on requirements set forth in state statute or regulation. Every agency can set their own state-specific requirements for each of their license types. NMLS performs compliance checks at the time of application for PE, and sets the CE requirement when the license is approved.

Q. What if an agency wants to change its state-specific education requirements?

A. State agencies can modify their state-specific education requirements at any time with advance notice. The advance notice is required to ensure industry is aware of the new requirement and so course providers can modify courses.

Q. What happens if an agency changes its PE or CE hour requirements?

A. If there is a change to PE requirements any applicant will be required to meet the new requirements on or after the effective date of the new requirement. For example, if an agency changes their PE requirement from 2 hours to 4 hours of state-specific education effective July 1, any application filed and in a pending status as of June 30th, will remain compliant for having met the 2 hour requirement. Any application submitted on or after July 1 will not be accepted if the individual has not completed the 4 hours of state-specific education.

If a state agency changes its CE requirements at any time during the calendar year, all MLO’s licensed with that agency will be required to meet the new hour requirement even if they were already CE compliant. For example, if an agency had a requirement for 8 hours of CE on 1/1/2017, and then the agency changes their requirement to include 1 hour of state-specific CE effective July 1, 2021, any MLO that was already CE compliant as of 6/30/2021 will now have to complete the 1 hour of state-specific education.

Q. If I work for a commercial bank or other federally chartered institution, do I need to take the SAFE-required education courses?

A. Non-state-licensed MLOs do not have the same formal CE requirements as state-licensed MLOs. The CFPB’s final rule on Reg Z (Part 1026.36(f) states in part:

Loan Officers will receive periodic training covering Federal and State law requirements that apply to the individual loan originator’s loan origination activities. Unlike for state licensed MLOs, the final rule is not prescriptive on the education requirements and is deliberately board as it is intended to take into consideration the types of activities a registered MLO performs daily.