Case Scenarios

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Can a Mortgage DBA Be Transferred from NEXA to C 2 C Mortgage Through the NMLS

Can a Mortgage Company DBA Be Transferred from One Employer to Another Through NMLS?

Posted by Gustan Cho, NMLS 873293
Gustan Cho Associates
Former Westmont, Illinois Branch Manager under NEXA Lending
New Employment: Coast 2 Coast Mortgage Lending, LLC

Background

I recently submitted my resignation from NEXA Lending. While at NEXA, I operated the Westmont, Illinois branch under my DBA, Gustan Cho Associates. The DBA name Gustan Cho Associates has been used for years in mortgage lending, consumer education, SEO content, borrower outreach, and national mortgage branding.

My new employment is with Coast 2 Coast Mortgage Lending, LLC. I now need NEXA Lending to surrender, release, cancel, or otherwise remove the Gustan Cho Associates DBA from its company and branch licensing records, depending on how each state and NMLS handles the process.

The main question is whether this DBA can be transferred or reassigned to Coast 2 Coast Mortgage Lending, LLC instead of having NEXA cancel it and then requiring me or Coast 2 Coast Mortgage Lending to reapply for the same DBA in many of the states where it was previously registered.

Main Question for Mortgage Compliance Experts

Can the DBA “Gustan Cho Associates” be transferred from NEXA Lending to Coast 2 Coast Mortgage Lending, LLC through NMLS or state regulators?

Or does NEXA first need to cancel, surrender, or remove the DBA from its records before Coast 2 Coast Mortgage Lending, LLC can apply to use the same DBA in each applicable state?

I understand that NMLS may treat DBAs as “Other Trade Names” on company licensing records. I also understand that each state may have its own rules for DBA approvals, branch licensing, assumed name filings, secretary of state filings, regulatory approval, fees, and timing.

Why This Matters

The concern is timing, cost, licensing continuity, branding continuity, and consumer confusion. Gustan Cho Associates is an established mortgage brand. If the DBA must be canceled first and then refiled state by state, that could create delays, additional fees, duplicate work, and possible interruption in marketing, licensing, advertising, branch records, and consumer-facing disclosures.

If there is a compliant way for NEXA to release the DBA and for Coast 2 Coast Mortgage Lending, LLC to assume or apply for that same DBA without unnecessary delay, I would like to understand the correct process.

Current Status from NEXA Lending, Coast 2 Coast Mortgage Lending, and Gustan Cho Associates

Al listed state termination fees for Gustan Cho Associates totaling $499.15 for the 50 states Gustan Cho Associates is a DBA of NEXA Lending. I asked whether those termination fees could be charged to my ledger reserve of Gustan Cho Associates at NEXA Lending..

June advised that my ledger needs to be audited before approving any deduction from the reserve. Al is waiting for that response.

I also asked about tracking unreceived credits tied to the 12% federal tax withholding issue. Al looped in Von and Miriam for assistance.

I asked Al whether the DBA can be transferred to my new employer for a fee instead of being canceled and refiled state by state.

I also asked whether I could remain sponsored by NEXA in states where Coast 2 Coast Mortgage Lending, LLC is not yet licensed, assuming this is allowed by state law, company policy, compliance rules, and NMLS sponsorship requirements.

The last email response from Al only provided my home email address. I have not yet received a clear response on the DBA termination progress, possible DBA transfer options, or tax withholding credit tracking.

Questions for Experts, Compliance Officers, Attorneys, and NMLS Specialists

• Can a mortgage DBA be transferred between two licensed mortgage companies?
• Is there any NMLS or state regulator process that allows a DBA or “Other Trade Name” to be transferred from one company to another, or must the first company remove it and the new company file for it separately?
• Does the answer depend on the state?
• If the DBA was used in multiple states, does each state decide whether the name can be transferred, released, amended, or refiled?
• Are there states that allow a smoother transition than others?
• What is the cleanest compliance process?

Would the Proper Process Be:

• NEXA removes Gustan Cho Associates from its NMLS company/branch records;
• Coast 2 Coast Mortgage Lending, LLC adds Gustan Cho Associates as an approved DBA or Other Trade Name;
• State regulators review and approve the DBA where required;
• Advertising, websites, branch records, and disclosures are updated after approval?
• Or is there another cleaner process?

Can NEXA surrender the DBA without creating a gap?

• Is there a way to coordinate the release by NEXA and the filing by Coast 2 Coast Mortgage Lending, LLC so there is no unnecessary licensing or advertising gap?

Who controls the DBA if the brand name belongs to me?

• If Gustan Cho Associates is my long-standing brand, and it was used under NEXA only because I operated a branch there, does NEXA have any continuing right to hold the DBA after my resignation?

Can I remain sponsored by NEXA in states where Coast 2 Coast Mortgage Lending, LLC is not licensed?

• Is dual sponsorship or temporary sponsorship allowed in any states when an MLO moves companies, especially if the new company is not licensed in certain states?
• If allowed, what disclosures, supervision, company approvals, and conflict checks are required?

Are termination fees normally charged to a branch ledger or reserve?

• If state termination fees are tied to ending the DBA or branch licensing relationship, can those fees normally be charged to the branch P&L, ledger reserve, or other reserve account, assuming the ledger is audited and funds are available?

What documentation should I request?

• Should I request a state-by-state list showing:
• Which states currently list Gustan Cho Associates as a DBA;
• Which branches are tied to the DBA;
• Which state regulators require termination filings;

Which Fees Apply;

• Which filings have been submitted;
• Which approvals are still pending;
• Whether the DBA name is available for Coast 2 Coast Mortgage Lending, LLC to file?

Goal

My goal is to handle this professionally and compliantly. I am not trying to create confusion between companies, regulators, borrowers, or referral partners. I simply want to know the proper way to transition the Gustan Cho Associates DBA from NEXA Lending to Coast 2 Coast Mortgage Lending, LLC without unnecessary delay, duplicate filing, or avoidable state-by-state complications.

Any guidance from mortgage compliance professionals, NMLS experts, licensing attorneys, state regulators, branch managers, or AI research tools would be greatly appreciated.

• This discussion was modified 3 days, 14 hours ago by  Gustan Cho.

Do you know anyone who can do Cashout Chapter 13 Buyout. January 2025 filed, four late payments, in the past 12 months. Value is $315,000, 80% cash out on current FHA loan, owe $30,000 for Buying out Chapter 13 Bankruptcy balance. Owes $178,000. Pennsylvania.

Have a very important question about HUD guidelines on originating FHA loans as a mini-correspondent lender. I am getting a lot of conflicting answers and hope you can help me to get to the bottom line. Many mortgage brokerage companies licensed in multiple states with a large size of NMLS licensed mortgage loan originators are also mini-correspondent lenders on FHA, VA, and conventional loans. Almost all mortgage brokerage companies offer both types of compensation, W2 and 1099 for its NMLS licensed MLOs depending on each state rules and regulations. One company in general, which I will call ABC Mortgage Broker, has all the necessary requirements to be able to become a HUD-Approved mini-correspondent lender on FHA loans besides being a mini-correspondent lender on VA and Conventional loans and a mortgage broker on FHA, VA, USDA, conventional, and non-QM loans. However, it is stopping them from becoming HUD approved mini-correspondent lender on FHA loans because someone has told them that you cannot be a mini-correspondent lender if you are paying your MLOs 1099 commission. About half the company gets paid 1099 and the other half gets paid W2s. Is there some truth behind this statement? I know for a fact certain companies are mini correspondent on FHA loans, and they have both 1099 and W2 MLO compensation. So who is right and who is talking out of their asses? Thank you in advance.

• This discussion was modified 3 days, 8 hours ago by  Sapna Sharma.

Do you know of any wholesale mortgage lenders that offer down payment assistance on FHA loans via manual underwriting? What are the eligibility requirements for the manual underwriting down payment assistance FHA loan program? Is it forgivable or non-forgivable? Is the DPA treated as a second mortgage and if so at what interest rate? I have many borrowers who want to purchase a house during Chapter 13 Bankruptcy repayment plan, and they will all be manual underwriting FHA loans.

I was referred to you by Julio and Hector Munoz and Dimitri Slovek. I am reaching out in hopes that your team can assist my wife and me with obtaining a mortgage despite a unique credit reporting situation.

My wife and I filed a Chapter 13 bankruptcy on March 18, 2024. However, after carefully evaluating our financial situation, we made the decision to voluntarily dismiss the bankruptcy because we believed it was the best path forward. The bankruptcy case was officially dismissed and closed in April 2025, a little over a year ago. Rather than remain in a repayment plan for years, we chose to rebuild our finances independently, honor our financial obligations, and improve our credit.

Since that time, we have worked diligently to restore our credit and strengthen our financial profile. Today, our situation is as follows:

My Credit Profile

• The Chapter 13 bankruptcy is reporting only on my Experian credit report.
• I have one charge-off reporting only to TransUnion.
• I have no other negative accounts.
• All remaining accounts are current, paid as agreed, and in good standing.
• My credit scores are currently in the mid-600s.

My Wife’s Credit Profile

• The bankruptcy is reporting only on her TransUnion credit report.
• It has already been removed from her Experian and Equifax credit reports.
• She has no other negative accounts.
• Her credit scores are in the low 700s.

Our current lender has advised us to wait until the remaining bankruptcy tradelines are removed from the final credit bureaus before proceeding with our mortgage application. Unfortunately, despite numerous disputes and providing documentation from the bankruptcy court, PACER, and LexisNexis supporting our position, the remaining reporting has not yet been corrected. We simply do not know how much longer the credit reporting agencies will take to resolve these issues.

Aside from these isolated reporting issues, we believe we are strong mortgage candidates. We both have stable employment, strong and consistent income, several years of employment history with our respective employers, and an excellent recent payment history. Since the dismissal of our bankruptcy, we have been intentional about rebuilding our credit and maintaining responsible financial habits.

In addition to my professional career, I serve as the senior pastor of a rapidly growing church. As our ministry continues to expand, it has become increasingly important for my family and me to relocate closer to our church and congregation. Living nearer to the people we serve will allow me to better fulfill my pastoral responsibilities and be more present for the community.

We are not asking for special consideration; we are simply asking that our overall financial picture be evaluated rather than having our application delayed solely because of a bankruptcy that remains on one credit bureau due to an unresolved reporting issue. We are prepared to provide documentation regarding the bankruptcy dismissal, our income, employment, tax returns, bank statements, and any other information necessary to support our mortgage application.

If your team has experience helping borrowers in situations like ours, we would greatly appreciate the opportunity to discuss our options. We would be grateful for your honest assessment of whether you believe you can help us obtain financing despite these remaining credit reporting issues.

Thank you for your time and consideration. We sincerely appreciate the opportunity to present our situation and hope to have the privilege of working with your team.

I’m an active-duty U.S. Navy First Class Petty Officer currently stationed in Japan and preparing to return to Mississippi.

I’m looking to purchase my family’s first home using my VA home loan benefit. My wife, son, and I are looking in the $240,000–$250,000 price range.

I’ve been watching your videos about VA loans for borrowers with lower credit scores and manual underwriting. I used your DTI calculator, and my debt-to-income ratio is approximately 41.8%.

Over the past few months, I’ve been working hard to strengthen my mortgage file. I recently resolved two collection accounts, I’m continuing to save for the home-buying process, and we currently have approximately $12,500 in savings.

I do have some previously reported late payments on my credit history, but all of my accounts are current today, and I’ve submitted goodwill requests to two of my creditors because those late payments resulted from autopay issues that I corrected as soon as I became aware of them.

Before I spend money on applications, I’d like to know if my file is something your team would realistically consider for a VA loan, and if so, what documents you would need from me to begin the pre-approval process.

Thank you for your time, and I look forward to hearing from you.

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CASE SCENARIO: ​I am selling my home and my proceeds from the sale of my home will be about $60,000 to $70,000 an my next home. My goal is to lower my mortgage payments. Can Gustan Cho Associates help me get approved for a home loan with a large down payment on a descent house with lower monthly payments?

I just read a post from FaceBook Internal Group and someone posted the text below. There are mortgage broker companies that claim loan officers will make 275 basis points and the company just charges a per file fee. C2C charges a 25 bps off the 275 and another 30 bps for a total of 55 bps so the loan officer nets 220 bps up to $2 million. Companies like Barrett Financial, C2 Financial Group, Loan Factory all compensate the loan officer the full amount of 275 bps and charge a per file fee. I wanted to know if these companies they charge a per file fee are playing games where they are making a hidden compensation on the back end where they get a silent kick back from the wholesale lender. Please read the post below:

Just played a fun little game with a recruit from Loan Factory. Guess we could call the game, “The $595 Flat Fee is BullSh!t Game.” I had heard about companies putting in BP’s into the rate sheet before sharing what an LO thinks is a truly raw rate sheet, that isnt really raw.

We put in the same exact scenario 800 Fico, 750K Price at 75% LTV, Purchase, SFR, impounds included, owner occupied. I used Rate Checker at zero comp and he used zero for his. My cost at Pennymac, which was a place we both had in common. on the rate we selected may have been 6.375% or 6.5%, our rebate was 1.810. His was 1.016 Was a difference of $5715 so add the $595 flat fee and we are $6310 better.

I kind of already sold him on building a downline, but that just kind of pissed him off about his own company. Happy hunting!

• This discussion was modified 3 days, 8 hours ago by  Sapna Sharma.

Never used a contract mortgage processor and I normally process my own loans or my LOA will assist. Can ypu please advise me on how contract mortgage processors work? I know you pay the contract preocessing company on a case by case basis once the loan closes. How much do contract processors charge per file? I am also considering hiring an inhouse mortgage processor and comparing what type of processor is better for my small mom and pop mortgage broker. What is the going rate on a full time mortgage processor? Can I hire a contract processor where the contract processor works with the mortgage processing company and myself, an independent mortgage broker at the same time? I would be hiring the contract mortgage processor for my files and pay her a base plus commission and the contract processor will also work for her contract processing company in dependent and separate from me. Thank you in advance.

I had a lease on an office building for three years and gave landlord notice that I was not renewing my lease. What happens if office building landlord does not return security deposit return from office building in Oakbrook Terrace Illinois

As a mom and pop mortgage broker owner with a small operation of three licensed loan officers, one full-time processor, and one full-time loan officer assistant and licensed in three states, the cost of a tri-merger credit report is becoming more and more unaffordable. I remember when a tri-merger credit report from Credit-PLUS cost $28.00 and a soft pull from one credit bureau cost $2.00. I have not been doing a lot of production but am starting to. Let me get this straight. A tri-merger hard pull costs $127.00 dollars per borrower? How about if you add a co-borrower or co-borrowers? What if you have one main borrower and two non-occupant co-borrowers? Would that cost $127.00 times three people so $381.00? How much are soft pulls? I heard many companies are sending out payment links for the mortgage applicants to pull their own hard pull tri-merger credit report where the borrower pays and get a copy of the tri-merger credit report and the loan officer gets sent a copy of the tri-merger credit report. By having the borrower pay the tri-merger credit report, the borrower does not get charged credit report fees at closing, correct? Normally, if the loan officer pulls credit and the mortgage broker company pays for it, does the lender charge a premium for credit reporting fees or the $381.00 just gets charged? How would you present to the borrower on directing them to go to the payment link and pay for the tri-merger credit report? Thank you in advance.

https://www.youtube.com/watch?v=4lJGBit9D44

If I were to surrender my mortgage brokerage and put it in hibernation and do a lateral transfer to a national mortgage brokerage company that is licensed in most of the 50 states, it there a deposit I would have to pay or empty credit card OR am I going to start off with a large negative balance on my P and L due to licensing transferring for my licensed loan officers, and myself. How about my hourly and salaried employee? Let’s take a hypothetical case scenario where I start with a national mortgage brokerage company ABC Mortgage Broker. I am on a P and L. Things go by smoothly where we are lucky to not run in the red and are able to pay our bills. What happens if all of a sudden a lot of loan fall through and we are having a slow month and are running short to make good on all of our bills. I will assume the basics such as electricity and other utilities will get paid or I can use my business credit card but how about the big ticket expenses like payroll for salaried and hourly employees. Will the parent company, ABC Mortgage Broker suspend payroll or will they need to wait until my P and L goes in the positive. The employees I am talking about are two mortgage processors and three loan officer assistants and are paid hourly and salary via W2. Their paychecks are issued on the first and fifteenth of the month with taxes being taken out. I know the mortgage industry has been rough the past two years and many mom and pop mortgage broker owners are struggling with not meeting expenses with incoming revenues. I am in Lake County, Illinois and I know both the Federal and State Department of Labor have strict laws, rules, and guidelines concerning making timely payroll payments. Can anyone advise? Thank you in adviance.

https://www.youtube.com/watch?v=HyrG4jolIjk

Have a case scenario for a client of a loan officer. Borrower inherited a $3 million dollar home in Fort Lauderdale. Waterfront property. The land is worth $2 million. Free and clear. Wants to borrower $300,000 via private or hard money but does not want to get homeowners insurance because the insurance carrier will want the house fixed before insuring it. Even if the house got destroyed, the lien holder/lender will not get hurt because the land itself is $2 million. The house was built in 1950 and could be a tear down. Advise would be appreciated.

Hello,
I have a question I was hoping you can answer.
If I have a home currently under a natural disaster forbearance that I end with a disaster loan modification will there be a waiting period to qualify for a new mortgage ?
I’m looking to rent this one out and buy a home somewhere else.

Thank you,

I need to buy a house and I got denied with a lender who was extremely incompetent where I got pre-approved and at the last minute I got denied due to my debt to income ratio. I am trying to buy a house for $200,000. My situation is I have full time employment. However, in 2024, I worked 40 hours consistently and made 80,000. However, in 2025, I only made 50,000 because my hours was reduced to a minimum of 32 hours due to going to a certificate training program for work. I am still classified full time since I work between 32 and 36 hours. I will be done with the certified training program in June 2026. I also have two newer vehicles under my name which is 780 per month for mine and 600 per month for my fiancee. This pushes my debt to income ratio to 70% back end with my father included as non-occupant co-signer. What solution do you have on me qualifying and getting approved for an FHA loan? Any ideas would be greatly appreciated. Is there any way my fiancee can take the hit on the vehicle he is driving and paying for even though it is under my name? He cannot refinance under his name because he went through a divorce and has tons of recent derogatory tradelines.

Can I buy a house with bad credit?

IS 12 MONTHS CANCELED CHECKS REQUIRED TO QUALIFY FOR A MORTGAGE? Is there a faster way of getting rid of the record of debt settlement on your credit report? Is achieving a 700 PLUS FICO credit score possible one year after a bankruptcy discharge?

Are you in a spot where you have to make some important financial decisions concerning your home? Is it better to do a big remodeling of your home before you put it on the market and increase the asking price or just leave it as is and ask for a lower price?

Could I finance land only? A site-built home or mobile home would come later after I’ve paid off the land. Are down payments on land higher? Are credit restrictions tougher?

FICO 5, 4, 2 is 610, 569, and 599. We have 4-year-old unpaid COs (job loss, very sick child). Pre-approved with different lenders from $173k (low end) to $225k (high end). the single borrower makes $45k, has a car payment of $370, and has low credit card limits with under 5% util. Excellent VOR and flawless payment history from the past 24 months and on. I made an offer on a house and was accepted for $190k, but I am now curious about other lenders. We’ll need manual underwriting, won’t we? Can GCA FORUMS Mortgage Group do manual underwriting? Are they a direct lender? Can they help us make this dream a reality?

In California, to refinance a property I owned before marriage does my spouse need to sign?

Underwriting wants me to write a letter on my late payments and charge the account off. What should I write?

In California, to refinance a property I owned before marriage, does my spouse need to sign?

Va loan with a 500 credit score, any way that has ever been done. Lady was married spouse passed and then she got cancer. Which she is cancer free now. So they have foreclosed on the home she is living in that was her husbands. She was not on loan. She is an RN, I know VA is not so much credit score. This below picture of info came from a Realtor friend. We would love to be able to help get some way, if possible purchase the home that foreclosed. She is still living in it still. She is an heir to property, so I was unsure how it would affect. As her name is on deed but not mortgage.

Will bank overdrafts disqualify me for a mortgage loan approval?

I was on a call, not sure which one about assignments. Commented, stating some lenders allow assignments, and buyers can close a loan with assignments. Did I hear it right? Like years ago, before Obama, my husband was flipping.

He helped a friend out, and we did some work. The buyer did a conventional loan. I did not do the loan. We did back-to-back closings,

Assignments have really gone crazy here. So, the state made some new rules because of it.

I personally think one was getting taken advantage of.

So I am asking that the form you provided us from Utah is awesome.

Can one do an assignment on a standard conventional loan? If so, I figured it would be just a few investors. How do I find them?

I am seeing opportunities with our new products. Where I may get a chance to get a foot in the door. My old-school investors, are now running investment groups and doing classes and things with them. A few of them are on a national level.

I will talk to you later about that and a few other things.

I am terrible at email.

• This discussion was modified 1 year, 4 months ago by  Sapna Sharma.
• This discussion was modified 1 year, 3 months ago by  Sapna Sharma.

One thing about mortgage lending is every case can have its own separate case scenario. There is always a unique case scenario for each individual borrower. We  will go over the hundreds of case scenarios we encounter as loan officers.

How do 401k Loans Effect a Mortgage Application? Can someone get a mortgage if they have a 401k loan and does it count against them?

What are the Alternative Credit Tradelines, when and how to use?

What happens if you are in the VA loan process and the property has issues and you can’t close? Can you just find another with the same price or less? Or does that mean you would have to file for court approval again?