How Do Contract Mortgage Processors Comply With the New State Licensing Requirements?

There are thousands of mortgage processorsThen you can have your primary customer
acting on a contract basis in the United States.sponsor your mortgage loan originator license. This
The SAFE Mortgage License Act that passed inwill allow you to process loans for your primary
July 2008 requires contract mortgage processorscustomer on a 1099 contract basis. The problem
to be licensed by July 2010. How does the newis that if you want to have other customers, you
law affect contract mortgage processors?would have to set up your contract between
Obtaining mortgage loan originator (MLO) licensesyour sponsoring primary employer and the other
in multiple states can be very costly. What can acustomers. So when you want to get paid by
contract mortgage processor do to comply andyour other customers, the other customers
not break the bank?would have to pay your primary customer and
Let's first look at the definition of a contractthen your primary customer could pay you. This
mortgage processor under the SAFE Mortgageobviously poses a huge problem for most
Licensing Act. The Act defines a mortgagecontract processors since it is very unlikely you
processor as an individual that gathers documentswill find a primary customer that will be willing to
from borrowers and submits the documents to asign processing contracts with your other
lender, but does not take residential loancustomers. However, this is how the states are
applications. The Act then goes on to state that asaying it must be done. Some states may be
mortgage processor is exempt from mortgageimplementing this slightly differently, so I
loan originator licensing as long as they are a w-2recommend contacting the state or a licensing
employee of just one mortgage company. Thus aservice to determine how the state is interpreting
mortgage processor that is 1099 and/orthese requirements.
processes loans for more than one mortgageOption 3
company must be licensed as a mortgage loanYou can choose to obtain a mortgage company
originator (MLO) and is considered a contractlicense and a mortgage loan originator (MLO)
mortgage processor. If you are defined as alicense in each state you want to process loans in.
contract processor, then what are your optionsThis is the ideal situation, because then you do
for obtaining a license in each state you processnot have to be limited to just one employer as in
loans?option 1 and you do not have to have a primary
Option 1customer sponsor you and pay you for your
You can choose to become a w-2 employee ofother customers work as in option 2. However,
just one mortgage company and processthis is the most costly option. It usually costs
mortgage loans for only that one company. Thisabout $1,000 to $3,000 to apply for a mortgage
is probably not the ideal situation for mostcompany license per state. And some states
contract mortgage processors, but it may be thehave net worth requirements, experience
only option for some. The cost of licensing can berequirements, and bonding requirements that can
expensive and a license is required in each statebe difficult barriers to overcome.
you process loans. Also, as we will discuss shortly,If you are able to go this option, you will actually
you may need to obtain a mortgage companybe able to avoid the mortgage loan originator
license too. This is even more costly thanlicensing in many of the states by paying yourself
obtaining just the mortgage loan originator license.as a w-2 employee of your contract processing
The down side to this option is obvious. You can'tcompany, but the costs will still be much higher. If
continue to process mortgage loans for youryou are thinking of going this way, you will want
other customers. Also, it may be hard to find ato get licensed only in states you plan on
company that will hire you on a full-time w-2 basis.processing ten or more loans in each month. In
Most smaller companies just do not have thefact, most people that go this route will benefit
resources to maintain a full-time processor onfrom having a few contract processors work
staff.with them to offset the costs.
Option 2Conclusion
You can choose to obtain a mortgage loanThere are really no good answers to this dilemma.
originator (MLO) license in each state you want toIn fact, this may be one of the worst problems
process loans in. Then you can have your primaryfacing the mortgage industry right now that most
customer sponsor those mortgage loan originatorpeople are not even aware of. Plan for the
licenses. To get a mortgage loan originator license,business of contract processing to change
you will need to complete 20 hours of education,dramatically starting August 2010. And make sure
two tests, fingerprinting, credit check, and pay anto be prepared to fall under one of these 3
application fee between $100 and $400 per state.options or you could be out of business.