Nationwide Multistate Licensing System Updates
Next Phase in the Modernization Development Roadmap:
On September 20, 2025, the Nationwide Multistate Licensing System (NMLS) launched Phase Two of its six phase, six year Modernization Development Roadmap. Phase Two is focused on the individual application/license maintenance process and the Resource Center. Planned enhancements during this phase are intended to alleviate frustrations users have experienced. Smarter search features and streamlined workflows are promised. One enhancement will allow individual applicants to enter a core set of data that can then be used when applying for a mortgage license in other states.
Introduction of Mortgage Call Report Form Version 7:
Another major NMLS change impacts companies’ quarterly filing of the Mortgage Call Report (MCR) with the introduction of MCR Form Version 7.
Companies should prepare now for the changes made in MCR Form 7. The new filing requirements taking effect will cover activity beginning January 1, 2026. The MCR Form Version 7 definitions and instructions, sample, and upload schema can be found here.
TEXAS DEPARTMENT OF SAVINGS AND MORTGAGE LENDING UPDATES
RULES
Required Use of Electronic Surety Bonds:
Effective January 1, 2026, all residential mortgage loan servicers will be required to obtain and maintain a surety bond filed electronically through the NMLS, in accordance with 7 Texas Administrative Code Rule 58.107.
The electronic surety bond process is explained on the NMLS Resource Center website.
Required Use of Website Address in Correspondence:
Current SML regulations require residential mortgage loan originators (7 TAC § 55.200(c)), mortgage companies (7 TAC § 56.200(d)), mortgage bankers (7 TAC § 57.200(d)), and mortgage servicers (7 TAC § 58.200(d)) to include the company, banker, or servicer website address in all correspondence with an applicant or borrower.
This requirement includes email correspondence. The Department has indicated to us that the disclosure of an email address that uses the same domain as the website address is not sufficient to meet the requirements of these rules. Therefore, we recommend that supervised entities ensure that any email signature block includes the entity’s website address.
EXAMINATIONS
The Department maintains a list of Common Mortgage Exam Violations. The top violations for 2025 relate to unlicensed loan processors and loan originator assistants.
LICENSING
Fee Structure:
At its August 2025 meeting, the Finance Commission of Texas approved the Department’s fiscal year 2026 budget. The budget establishes licensing fees for FY2026, including fees for the annual renewal period, which began November 1, 2025.
There are no increases to existing fees for licensees and registrants.
Renewals:
Annual Renewal season began November 1, 2025. All licensees and registrants must renew by December 31, 2025.
Tips from NMLS for Licensees to Prepare for NMLS Renewal:
- Review your NMLS record – log in and check to make sure your profile is accurate and includes your current email and other information.
- Reset your NMLS password – update your password to ensure it is current.
- Consolidate your NMLS accounts – use your username and password to consolidate multiple accounts for convenient access and navigation.
- Review state-specific renewal requirements – state agencies begin publishing requirements, including deadlines and fees, in September.
- Access free, on-demand renewal training – CSBS develops a variety of resources for licensees to learn about the renewal process.
Items that will prevent renewal:
- Continuing education requirements for MLOs
- Mortgage Call Report requirements for Companies
- Active license items for all licensees and registrants.
Information on NMLS renewal process is available at the NMLS Resource Center under the Company and Individual Licensing Resources links.
Information on Licensing Status:
Current licensee/registrant base eligible for renewal: 54,018
Renewal Progress as of November 13, 2025: 37.9%
| Entity Type | Renewal Licenses | Requested (as of 11/13/25) | % Requested |
| Mortgage Loan Originator | 44,395 | 16,083 | 36.2% |
| Auxiliary Mortgage Loan Activity Company | 4 | 2 | 50% |
| Credit Union Subsidiary Organization | 4 | 3 | 75% |
| Independent Contractor Processor/Underwriter Company | 454 | 109 | 24.0% |
| Mortgage Banker | 383 | 243 | 63.4% |
| Mortgage Company | 3,672 | 990 | 27.0% |
| Residential Mortgage Loan Servicer | 260 | 126 | 48.5% |
Reinstatements:
Reinstatement period is from January 1, 2026, to February 28, 2026 (except for residential mortgage loan servicers).
New Reinstatement Fee:
Per Texas Finance Code Sections 156.2081 and 157.016, the renewal fee is increased to 150% of the base renewal license fee for those who do not timely renew and who seek reinstatement of the license.
This fee applies to Residential Mortgage Loan Companies and individual Residential Mortgage Loan Originators.
Common Reasons for Delay in Processing RMLO Applications:
Some of the most common reasons for a delay in the processing of an RMLO application are shown below:
- ACH payment. (10 calendar day hold on the receipt of the funds.)
- Current employer information does not match the Registered Location information.
- Mailing address does not match residential address.
- Not providing documents for Disclosure Questions that were answered “Yes”.
If applicable, these issues should be cleared before applying for an RMLO license.
If you have any questions about this memo, licensing, examination, or regulatory questions, please reach out to doug.foster@mortgagelaw.com or caroline.jones@mortgagelaw.com. Please note that our firm is available for all services and issues relating to residential mortgage lending. Our team can be accessed through www.mortgagelaw.com/people.
