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NMLS Individual, Branch, and Company Licensing and Transferring
I have NMLS mortgage licensing questions and hope you can help. I’m getting conflicting answers to my questions, even from the NMLS and mortgage licensing companies like Integrity Licensing. I manage a mortgage NET branch on a P&L platform, based in Indiana. I am a small net mortgage branch licensed in 30 states as a dba of Nexa Mortgage. Nothing bad about NEXA, and I get along with everyone there, including my co-workers and vendors. There is no ill will or bad reason for me to be looking to transfer my NMLS licenses, as well as a couple of MLOs. My questions are the following:
I am individually licensed in 30 states, and the mortgage net branch is licensed in 30 states. Can you please advise me on the best, smartest way to move companies from NEXA to C2C? Do I have a loan officer move first? Will the branch and individual NMLS licenses transfer from NEXA to C2C, or do I need to surrender the branch and start a new one? How about states such as Nevada, California, and Massachusetts, where it took me a long time to get my mortgage net branch and my individual NMLS. Are there any costs, fees, paperwork, or documents required for the new company? How about my name, One Capital Financial, which is a dba? How do I transfer my DBA to the new company? Can you please give me step-by-step guidance on the best, most efficient, and fastest way to make the move? How about our existing pipelines from the loan officers and the producing branch manager? My current branch, as well as I and MLO, are licensed in Hawaii, but the new mortgage company is NOT. I need to be licensed in Hawaii because I have many clients there. The owners of C2C said they will do everything possible to get the company licensed in Hawaii, so I am respectfully requesting your advice on the best, fastest way to get the corporation and/or my branch licensed in Hawaii. If you can give me step-by-step, easy-to-follow bullet points, it would be greatly appreciated.
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11 Replies
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Here is the clean way to look at this:
Your individual NMLS licenses do not “transfer” like a file being moved, but your individual licenses generally stay with you and become active under the new company only after the new company creates the NMLS relationship, requests sponsorship, and each state approves or recognizes that sponsorship. Your branch licenses are different. A branch license is normally tied to the sponsoring company’s NMLS record/MU3, so your NEXA branch license generally does not move over to C2C. C2C would normally need the proper company license first, then branch authority/branch licensing, then MLO sponsorships.
1. Biggest Rule: Do Not Resign or Surrender Anything Until C2C Is Ready
The biggest mistake would be ending your NEXA relationship before C2C has the proper company licenses, branch licenses, DBA approvals, and sponsorship ability in the states you need.
NMLS explains that company/MLO relationships and sponsorships are required for most state-licensed MLOs, and the company must create the relationship and request sponsorship through NMLS. NMLS also notes that sponsorship fees may include an NMLS processing fee and state agency sponsorship fees. (Nationwide Licensing System)
Best move: keep NEXA active until C2C confirms in writing:
- C2C is licensed in each state where you want to originate.
- C2C can sponsor you and your MLOs in each state.
- C2C has, or can obtain, the required branch licenses.
- C2C can approve your DBA/trade name use.
- C2C has a pipeline transition plan that does not violate NEXA, investor, warehouse, wholesale lender, disclosure, RESPA, or state rules.
2. Individual MLO Licenses: What Likely Happens
Your individual licenses in 30 states are attached to you, not NEXA. However, the active authority to originate is tied to sponsorship by a properly licensed company.
- The practical process is usually:
- You grant C2C access to your NMLS record.
- C2C creates an employment/company relationship with you in NMLS.
- C2C requests sponsorship for each state license.
- You update your MU4 employment history.
- Each state either approves the sponsorship, updates the license to active, or requests additional items.
In Nevada, for example, the state says that when changing employment, the MLO must update MU4 employment, terminate the old relationship if needed, provide the new employer access, and the new employer must submit sponsorship through NMLS. Nevada also states that the MLO is not authorized to originate while inactive and must be sponsored and approved before conducting business.
California follows the same basic concept: the MLO must be employed by and sponsored by a California DFPI licensee under the CFL or CRMLA. (DFPI) Massachusetts also allows reassignment/change of sponsorship through NMLS within one year after termination, with the required fee. (Legal Information Institute)
3. Branch Licenses: These Usually Do Not Transfer
Your branch license under NEXA is most likely a NEXA branch license, not a personal asset that can be moved to C2C.
The branch is normally filed under the company’s NMLS record on MU3. NMLS treats branch filings separately from company and individual filings, and branch amendments apply to existing branch licenses when changing the MU3 filing. (Nationwide Licensing System)
So the likely answer is:
- Your individual licenses can be re-sponsored by C2C.
- Your branch licenses likely need to be newly created or newly licensed under C2C.
- Your existing NEXA branch licenses should not be surrendered until C2C has replacement authority in place.
For hard states like Nevada, California, Massachusetts, and Hawaii, do not assume a simple switch. Have C2C’s licensing team pull the exact NMLS checklist for each state and confirm whether a new branch license, branch manager assignment, physical office requirement, DBA registration, bond rider, financial statement, control person update, or advance notice is required.
4. Should a Loan Officer Move First?
Yes, but only as a controlled test, not as a rushed move.
The smartest way is:
- Move one non-critical MLO first in a state where C2C is already fully licensed.
- Do not use Hawaii, Nevada, California, or Massachusetts as the first test state.
- Pick a state with lower complexity and no active high-value pipeline.
- Confirm how long sponsorship approval takes.
- Confirm whether the MLO shows active in NMLS Consumer Access.
- Confirm C2C’s onboarding, payroll, compensation plan, LOS, CRM, disclosures, lender access, and licensing support all work properly.
- After that test is successful, move the producing branch manager and the larger team.
5. What To Do About Existing PipelineThis is one of the most important parts.
Existing pipeline loans usually belong to the originating company or are controlled by the company’s policies, wholesale lender approvals, lock desk, broker agreement, disclosures, and compensation structure. You should not assume files can simply be moved to C2C.
The cleanest options are:Option 1: Close existing NEXA pipeline at NEXA.
This is usually the safest. Keep your NEXA branch active long enough to close locked, disclosed, submitted, approved, or conditionally approved files.
Option 2: Move only brand-new leads to C2C after licensing is active.
- This prevents disclosure confusion, compensation disputes, lender contract issues, and borrower disruption.
Option 3: Transfer selected files only with written approval.
- If a file must move, get written approval from NEXA, C2C, the wholesale lender/investor, compliance, and the borrower.
- Many files may need to be re-disclosed, re-locked, re-submitted, or restarted.
- My recommendation: do not move active pipeline unless absolutely necessary.
- Let NEXA files close at NEXA, and start new files at C2C only after the state, branch, sponsorship, DBA, and compliance pieces are fully active.
6. DBA / Trade Name: “One Capital Financial”
- A DBA/trade name usually does not automatically transfer from one mortgage company to another.
If “One Capital Financial” is currently approved under NEXA, then it is likely being used as an other trade name under NEXA’s company/branch licensing structure. C2C would generally need to:
- Approve the DBA internally.
- Confirm who legally owns the DBA/trade name.
- Register the trade name in each required state, Secretary of State, county, or state mortgage regulator system.
- Add the trade name to C2C’s NMLS MU1 as an Other Trade Name where required.
- Add the trade name to the applicable branch MU3 if the state requires it.
- Receive state approval before advertising or originating under that name.
- For Hawaii specifically, the Hawaii DFI says trade names can be indicated on the company’s MU1 for Hawaii, and trade names must be properly registered with Hawaii’s Business Registration Division before being used. (DCCA Hawaii)
7. Hawaii: Most Important State in Your Situation
Because C2C is not currently licensed in Hawaii, you cannot rely on your existing Hawaii MLO license alone. Hawaii business cannot be originated under C2C until C2C has the proper Hawaii company authority and can sponsor you properly.
Hawaii says every MLO, MLOC, and other person conducting mortgage loan origination activity in Hawaii must register with NMLS unless exempt. Hawaii also states that every individual MLO must be linked to or sponsored by a company, and Forms MU1, MU2, and MU4 may be required depending on the structure. (DCCA Hawaii)
Hawaii also has important physical office/branch requirements. Hawaii DFI states that licensed MLOCs must maintain a principal place of business in Hawaii, obtain approval for branch locations, and designate a manager at each office. (DCCA Hawaii) Hawaii law also says a branch manager must be physically present in the branch office and hold a Hawaii MLO license. (Justia)
Fastest Hawaii Path For C2C
- C2C should immediately do the following:
- Confirm the exact Hawaii license type needed in NMLS.
- File or prepare the Hawaii Mortgage Loan Originator Company license application.
- Register C2C to do business in Hawaii if required.
- Secure a Hawaii principal place of business or qualifying Hawaii office location.
- Designate a Hawaii branch manager who holds a Hawaii MLO license and can satisfy the physical presence requirement.
- Identify the qualifying individual. Hawaii’s FAQ says there is no residency requirement for the qualifying individual, but the individual must satisfy Hawaii MLO license requirements. (DCCA Hawaii)
Submit MU1 for the company.
- Submit MU2 for control persons/qualifying individuals as required.
- Submit MU3 for the Hawaii branch/principal office if required.
- Register any DBA/trade name, including One Capital Financial, before using it in Hawaii.
- Prepare fingerprints/background checks if required.
- Pay Hawaii/NMLS fees.
- Wait for Hawaii DFI approval before originating Hawaii loans under C2C.
- Hawaii’s published fee information states initial fees of $300 for a principal office MLOC, $250 for a branch office MLOC, and $200 for an MLO, with renewal fees also listed. (DCCA Hawaii)
8. Recommended Step-By-Step Transition PlanPhase 1: Build a State-by-State Licensing MatrixCreate a spreadsheet with all 30 states and columns for:
- Your individual license status.
- Your MLOs’ license status.
- NEXA branch license status.
- C2C company license status.
- C2C branch license status.
- DBA approval status.
Sponsorship fee.
- Branch manager requirement.
- Physical office requirement.
- Special documents.
- Estimated approval time.
- Do not move anyone until this matrix is complete.
Phase 2: Have C2C Confirm Company Authority
For each state, C2C should confirm:
- “We are licensed in this state.”
- “We can sponsor One Capital Financial in this state.”
- “We can sponsor each listed MLO in this state.”
- “We can license or register the branch in this state.”
- “We can use the DBA One Capital Financial in this state.”
- “We can accept new applications immediately after approval.”
- Get this in writing.
Phase 3: File Branch Applications Before Moving Production
- C2C should file branch applications in the states where branch licensing is required.
For hard states, start first with:
- Hawaii
- California
- Nevada
- Massachusetts
- Any state where approval took months the first time
- Do not surrender the NEXA branch until the C2C branch is approved or confirmed not required.
Phase 4: Test With One MLO
Move one MLO first in an easier state.
- Confirm:
- Access granted.
- Relationship created.
- Sponsorship requested.
- MU4 updated.
- State approval received.
- NMLS Consumer Access shows active.
- LO can originate compliantly.
- Payroll/compensation plan works.
- LOS/lender access works.
Phase 5: Move Gustan and Key MLOs
- Once the test is successful, move yourself and key producing MLOs in batches.
- Do not move everyone on the same day unless C2C’s licensing team is fully prepared.
Phase 6: Pipeline Cutover
- Use a clean date.
- Before cutover date: existing NEXA pipeline stays at NEXA.
- After cutover date: new leads and new applications go to C2C only in states where C2C is licensed, branch-approved, DBA-approved, and sponsorship-approved.
Phase 7: Retire or Surrender NEXA Branch Licenses Last
Only after:
- Pipeline is closed or transferred with written approval.
- Compensation is reconciled.
- Borrower files are accounted for.
- State reports are complete.
- Advertising has been updated.
- DBA usage has been removed from NEXA if needed.
- C2C authority is fully active.
9. Documents and Costs To ExpectExpect possible costs or paperwork for:
- NMLS sponsorship fees.
- State sponsorship fees.
- MU4 amendments.
- MU1 company filings.
- MU2 control person/qualifying individual filings.
- MU3 branch applications.
- Branch license fees.
- DBA/trade name registrations.
- Secretary of State foreign qualification.
- Registered agent.
- Fingerprints/background checks.
- Credit report authorizations.
- Surety bond or bond rider, if required by the state.
- Financial statements or net worth documentation for company licensing.
- Branch manager designation forms.
- State-specific checklists outside NMLS.
- NMLS says state checklists should be reviewed for additional requirements outside NMLS when changing employers. (Nationwide Licensing System)
10. My Practical Recommendation
The smartest and safest path is:
Do not “transfer” the whole operation at once.
Have C2C license the company and branch footprint first, especially Hawaii, California, Nevada, and Massachusetts. Then test one MLO. Then move yourself and the production team. Close old NEXA pipeline at NEXA unless there is written approval to move specific files. Add One Capital Financial as a C2C-approved DBA only after state trade name approvals are complete.
The one state I would not compromise on is Hawaii. Since C2C is not licensed there, you should keep your NEXA Hawaii authority active until C2C’s Hawaii company license, Hawaii office/branch structure, Hawaii branch manager, DBA approval, and your C2C Hawaii sponsorship are fully approved.
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This reply was modified 3 weeks, 6 days ago by
Gustan Cho.
mortgage.nationwidelicensingsystem.org
Creating Relationships and Sponsorships
Follow the steps to create a relationship with a Mortgage Loan Originator (MLO) in NMLS and request sponsorship of their license, which is required for most state-licensed MLOs.
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You are correct. The real question is cost timing, not the general mechanics.
My Direct Answer
If you can wait until renewal season, it is usually smarter and cheaper to move the individual MLO licenses and branch licensing to C2C in November/December.
Reason: NMLS renewals run from November 1 through December 31 for individuals and companies/branches. During renewal, you are already paying annual renewal fees to keep licenses active for the next calendar year. NMLS confirms that individuals and companies renew annually during that window, and that renewal requires payment of applicable fees.
If you move now, you may create duplicate or extra costs:
You may pay NMLS sponsorship/change fees now.
C2C may need to file new branch applications now.
You may pay state branch fees now.
You may pay DBA/trade name registration or amendment fees now.
Then, a few months later, you may pay renewal fees again for the same individual, branch, and DBA footprint.
NMLS also states that an MLO change of sponsorship fee is incurred each time a company requests to sponsor an MLO license, and the annual processing fee is charged during renewal per agency/license.
Individual Licenses vs Branch LicensesYour Individual Licenses
Your individual licenses are yours. You do not start from scratch in most cases. C2C would request sponsorship for your existing state licenses.
However, changing sponsorship now may trigger:
NMLS sponsorship/change fees
State sponsorship fees
MU4 amendment work
Possible state-specific requirements
Possible temporary inactive status if not timed correctly
Your Branch Licenses
Your branch licenses are the bigger cost issue.
Your current branch licenses are under NEXA’s company structure. They usually do not transfer cleanly to C2C like your individual NMLS license. C2C would likely need to create/file its own branch authority under C2C.
That means if you move now, C2C may pay for new branch filings now, and then renewal fees again in November/December.
Best Cost-Saving StrategyBest Strategy If There Is No Emergency
Wait until renewal season.
Start preparing now, but make the actual licensing move during the renewal window.
This avoids paying unnecessary duplicate branch, individual, DBA, and sponsorship-related fees.
Recommended TimelineNow Through October 2026: Prepare, Do Not Transfer Yet
- Have C2C build a state-by-state cost sheet for all 30 states.
- For each state, ask C2C to confirm:
- Does C2C already have company authority?
- Does C2C need a branch license?
- Does the branch license require a physical location?
- Does the DBA need state approval?
- What are the state fees?
- What are the NMLS fees?
- What happens if we file now versus during renewal?
- You should not move your main branch now unless there is a major business reason.
September / October 2026: Finalize the Move Plan
Before renewal opens, have C2C prepare:
- Your sponsorship requests
- MLO sponsorship requests
- Branch applications
- DBA filings
- State-specific forms
- Surety bond riders, if needed
- Branch manager designations
- Company/branch address decisions
- Hawaii licensing plan
November / December 2026: Move During Renewal
- This is likely the best time to transition.
- During renewal, you can coordinate:
- Individual license renewal
- C2C sponsorship
- Branch licensing/renewal decisions
- DBA approval
- MLO transfers
Pipeline cutoff
- This way, you are not paying now and then paying again at renewal.
What I Would Not Do
- I would not surrender your NEXA branch licenses at this time.
- I would not move all 30 states immediately unless C2C is already fully licensed and ready.
- I would not pay for duplicate branch licenses now unless the revenue justifies the cost.
- I would not move to Hawaii until C2C is licensed in Hawaii.
- I would not let your current licenses lapse if you still need production authority.
Hawaii Exception
Hawaii is different because C2C is not licensed there at the moment.
If Hawaii is important to your business, C2C should begin Hawaii company licensing as soon as possible. But you personally should probably keep your Hawaii authority under NEXA active until C2C is fully licensed and able to sponsor you in Hawaii.
In plain English:
Do not lose Hawaii to save renewal fees.
- If Hawaii took a long time to obtain, keep it active until the replacement is confirmed.
My Practical RecommendationThe best, cheapest, lowest-risk move is:
- Stay with NEXA through most of 2026 unless there is an urgent reason to leave.
- Have C2C prepare all 30 states in advance.
- Do not duplicate branch licenses mid-year unless absolutely necessary.
- Move individual sponsorships and branch setup during the November/December renewal window.
- Keep Hawaii active with NEXA until C2C has Hawaii company approval.
- Close the existing NEXA pipeline at NEXA and start new C2C production only after licensing is active.
Bottom Line
Yes, based on your concern about fees, waiting until renewal season is probably the smartest financial move.
You are already licensed in 30 states, and your branch is licensed in 30 states. Moving now may cause you to pay new sponsorship, branch, DBA, and state fees, then pay renewal fees again shortly afterward.
The only reason to move now would be if the business benefit of moving to C2C immediately outweighs the duplicate licensing costs. Otherwise, prepare now and execute during renewal.
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I am a branch manager and have 30 licenses with ten mortgage loan officers
I am thinking of moving to a larger company
The home office is in Los Angeles California
Can my loan officers and get sponsored by corporate office for my loan officers and I and get just sign up icensed on states with distance from residential to requriring states brick and mortar? My current branch with Barrett Financial, I had myself and the branch in 30 states. Since I am changing companies I like to be sponsored by Corporate on states that don’t have a physical location
11 states require individual MLOs live within 75 miles. My question is can I get sponsored by corporate in 19 states without distance to branch requirements and open a small office and get sponsored by my branch at the same time?
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You mean under one mortgage company but two different branch NMLS? What i know is if the company is the same company then yes you can get sponsor by two different btanch location
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This reply was modified 3 weeks, 3 days ago by Gustan Cho.
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This reply was modified 3 weeks, 3 days ago by
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Yes, in many cases this structure can work, but only if the new company’s compliance or licensing team sets it up correctly in NMLS and each state allows that model.
Your idea is basically:
For the 19 states without distance-to-branch requirements:
- You and your MLOs can be sponsored under the corporate or home office in Los Angeles, as long as the company is licensed in those states and those states allow remote MLO supervision from a corporate or approved location.
For the 11 states with distance or physical-branch requirements:
- You may need a licensed branch office closer to the MLOs or within the required distance, like the 75-mile rule, if the state requires the MLO to be connected to a branch or supervised location within that range.
- NMLS confirms that a sponsored MLO must be connected to either the company headquarters or a branch location in NMLS, and that the company designates a company or branch location for each MLO relationship.
The Key Point
You are not actually “sponsored by corporate” and “sponsored by the branch” as if they are two different employers. You are sponsored by the licensed company, but the company can assign the MLO to either a corporate office or a branch office location in NMLS, depending on state rules.
So the answer is:
- Yes, potentially.
- You can assign your MLOs to the corporate office in states that allow it, and have a licensed branch in states that require closer physical office or branch supervision.
- This must be handled on a state-by-state basis.
Your Small Office Idea
Opening a small office can help, but only if it is properly licensed as a branch when required.
A small office should not be used as an address unless:
- The company approves it.
- The state allows that location.
- The branch is licensed or, if required, registered.
- The branch manager is properly listed in NMLS.
- The MLOs are properly assigned to that branch or supervised location.
- NMLS states that a branch is submitted through the Branch Form MU3 after the company MU1 is filed, and branch managers listed on the MU3 must have individual NMLS accounts and complete MU2 forms.
Be Careful With Remote Work Rules
Many states allow remote MLO work, but remote work does not always exempt MLOs from branch licensing requirements. Some states allow an MLO to work from home as long as the home is not advertised as a branch, no borrowers meet there, records are not stored there, and supervision/security rules are followed.
For example, North Carolina says a principal office or branch may not be located at an individual’s home, but an MLO may work remotely if records remain at the principal office or registered branch. (nccob.nc.gov)
This is the kind of detail you need to watch for. Just because remote work is allowed does not always mean there are no branch requirements.
The Biggest Risk In Your Plan
The biggest risk is assuming the Los Angeles corporate office can support every license just because the company is bigger.
That may be true in some states, but not in states with:
- 75-mile supervision rules
- In-state branch requirements
- Brick-and-mortar requirements
- Qualified branch manager requirements
- State-specific branch licensing
- Restrictions on remote origination locations
- Requirements that files and records remain at licensed locations
Some states may reject the sponsorship or put the MLO license in an inactive or deficient status if the company location or branch relationship does not meet state requirements.
For example, Wisconsin explains that if sponsorship is removed or the company is not licensed, the MLO license becomes approved-inactive, and the individual cannot conduct business until sponsored by a licensed company.
Important Transition Issue
When you change companies, your licenses do not just “transfer” as many people think. The new company must create the NMLS relationship and sponsor your licenses. NMLS describes the sponsorship process as access, relationship, and then sponsorship.
Temporary Authority may help in some cases, but it comes with strict requirements. NMLS says the MLO must usually have been registered for one year or licensed for 30 days before applying, cannot have a break in service of more than 14 days, and must be a W-2 employee of the state-licensed company in the application state.
Practical Answer For Your SituationThe cleanest structure is usually:
- Corporate sponsors you and your 10 MLOs in the states with no branch-distance problem.
- This works if the company is licensed in those states and the state allows remote or corporate location supervision.
- You open or maintain a licensed branch for the states with distance, brick-and-mortar, or branch-supervision rules.
- That branch should be licensed in the required states and connected to the correct branch manager.
- Your MLOs are assigned in NMLS to the correct supervised location.
- For some states, that may be corporate. For others, it may need to be your branch.
- Do not rely on just one Los Angeles office for every state until compliance confirms each state.
- California corporate home office may be allowed in some states and not allowed in others.
My RecommendationBefore moving, ask the new company’s licensing department for a written state-by-state transition matrix showing:
- Which of your 30 states can be sponsored by the corporation
- Which states require a licensed branch
- Which states have 75-mile or distance rules
- Which states require a brick-and-mortar office
- Which states require a branch manager or a qualified individual
- Which states allow remote work without branch licensing
- Which licenses can use Temporary Authority
- Which licenses may go inactive during the transition
Your plan can work, but only if the new company has the licensing setup to support both models: corporate sponsorship, where allowed, and branch-based sponsorship
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How much does it cost for Branch licensing if you want to open a net mortgage Branch of New American Funding? I want to get licensed in 10 states. I am a DBA currently of a CrossCoubtry Mortgage Net Branch
How can I transfer my DBA out of Crosscountry Mortgage to New American Funding and how much does doing a DBA cost? Thank you.
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Great question. I operate a net mortgage branch. Both my branch and myself as an individual are licensed in 48 states, including Washington, DC, Puerto Rico, and the U.S. Virgin Islands. I am also a DBA of the mortgage broker company. Prior to my current sponsoring mortgage broker, I operated under my own trade name and not a DBA. I remember getting conflicting answers to this very question you are asking and even to this very day, I am getting conflicting answers which I will find out.
Transferring a CrossCountry Mortgage net branch license or DBA to New American Funding is not a simple process. CrossCountry Mortgage branches are tied to CrossCountry’s NMLS records. Any approvals or changes to branch, DBA, or MLO sponsorship will be at New American Funding’s discretion and processed through its NMLS records. New American Funding, LLC, is listed on NAF’s state licensing page as NMLS #6606.
Estimated Costs to Open a New American Funding Branch in 10 States
Total costs depend on the states involved, their licensing requirements, the process for establishing a New American Funding branch, and onboarding expenses. Additional fees may include compliance, technology, and DBA review costs.
Confirmed Costs:
- NMLS charges a $25 processing fee for each Form MU3 filed.
- For 10 states, this totals $250.
- This amount covers only the NMLS processing fee.
- Each state may impose additional fees for branch licensing, registration, amendments, or renewals.
- For example, New Mexico charges a $500 branch license fee and a $500 annual renewal fee.
- Texas and Utah have their own fee structures that vary by licensing type and include both NMLS and state application fees.
- Upper range: $7,500 to $15,000 or more
- If the 10 states have higher fees, additional licensing requirements, mandatory physical offices, registered DBA filings, legal reviews, compliance consulting, or state-specific advertising approvals, total costs will increase significantly.
Key Point: Branch Licensing Is Typically a Company Expense, Not a DBA Expense
Branch licenses are issued to the mortgage company, not the DBA. If you transition to New American Funding, the branch will be established under New American Funding, LLC.
- In NMLS, the Branch Form MU3 is linked to the company’s NMLS records.
- A branch filing can only proceed after the Company Form MU1 is completed.
Accordingly, New American Funding Would Likely Need To:
- Add or approve your branch location.
- File Form MU3 branch applications or necessary branch amendments.
- Acknowledge the states where your branch needs to be licensed.
- Add your DBA/trade name where applicable.
- Sponsor your MLO license under NAF in the necessary states.
How DBA Transfer Usually Works
- Your DBA will not automatically transfer from CrossCountry Mortgage to New American Funding.
- NMLS considers DBAs as Other Trade Names.
- Your DBA will not transfer automatically from CrossCountry Mortgage to New American Funding.
- NMLS says that licensees do not need to include “DBA” before the trade name; it should be recorded as advertised or as in the documents.
- NMLS states that applicants and licensees must include all Other Trade Names as indicated on a Branch Form on the Company Form.
- In summary, for your branch to operate under the name “Your DBA Name,” New American Funding must properly include and authorize the name in its NMLS company and branch records as required in a branch license.
Estimated DBA Costs Include:
- State/county assumed-name filing: usually between $10 and $150+, depending on the area.
- Multiple states: $100 to $1,500 or more, depending on the number and location of filings.
- Attorney or compliance assistance: $500 to $2,500 or more, if needed.
- NMLS trade name amendments: State filings and reviews may be required, depending on the state.
- Internal company review: May incur additional costs, depending on New American Funding’s approval procedures.
- Some states require evidence to ensure the firm legally uses the trade name.
- For example, a Texas branch checklist states that if a branch is operating under an “Other Trade Name,” “Assumed Name,” or “DBA,” it must be listed under Other Trade Names and may require an assumed-name certificate to be filed with the Texas Secretary of State.
Can You Retain the Same DBA Name?
It is possible, but you must first verify the following:
- Determine legal ownership of the DBA.
- If it is filed under your personal or branch entity, the process is usually more straightforward.
- If CrossCountry owns the DBA, you may need a release or a new filing.
- Many mortgage companies closely control branch branding, so even if a state allows the DBA, New American Funding compliance may not.
Verify whether the 10 states permit the use of the DBA for mortgage advertising. Some states have stricter regulations on advertising, branch names, and trade names, even if the DBA is properly registered.
How to Transition from CrossCountry Mortgage to New American Funding
The Following Steps Are Recommended:
Step 1: Obtain a Written Offer from New American Funding
Obtain a written branch offer from New American Funding before leaving CrossCountry.
Ensure it addresses the following questions:
- Will CrossCountry approve your DBA?
- Will CrossCountry approve your branch location?
- Which 10 states will CrossCountry sponsor you in?
- Who is responsible for state branch fees?
- Who is responsible for MLO sponsorship fees?
- Who is responsible for DBA filings?
- Who is responsible for NMLS MU3 branch filings?
- Will your LOs follow you to CrossCountry?
- Will compliance approve your website, phone number, CRM, email, marketing, and social media?
Step 2: Confirm DBA Details with New American Funding
Ask NAF compliance or licensing:
- Can New American Funding add my DBA as an Other Trade Name on MU1 and MU3 for the states where my branch will operate?
- NMLS allows companies to amend Other Trade Names through an Advance Change Notice process when adding, modifying, or deleting a trade name on the company MU1 filing.
Step 3: Review Your CrossCountry Agreement
Before you move anything, review your CrossCountry net branch agreement for the following restrictions.
- Marketing asset ownership
- Phone number ownership
- Website/domain ownership
- CRM/database ownership
- Pipeline restrictions
- Branch P&L obligations
- DBA ownership language
- Outstanding chargebacks, EPOs, or branch losses
Step 4: Officially Resign
- Proceed carefully to avoid licensing lapses, borrower confusion, RESPA-related issues, advertising complications, and disruptions to your loan pipeline.
- Do not assume that CrossCountry will permit the transfer of live loans to New American Funding unless a specific transfer process is established. nsorships
- For each moving MLO, their NMLS sponsorship must be changed to New American Funding.
- NMLS indicates that the MLO change-of-sponsorship fee is $35.
- At $35 per sponsorship, transferring 10 loan originators would cost $350, excluding any additional proprietary or state-specific fees.
Your Situation
If you are a DBA of a CrossCountry Mortgage net branch and plan to establish 10 branches with New American Funding, the estimated costs are as follows:
- Branch licensing, state setup, and NMLS: $3,000 to $10,000 or more
DBA registration and trade name setup: $500 to $3,000 or more
MLO sponsorship transfers: $35 per transfer in NMLS
Legal or compliance review: $1,000 to $5,000 or more, if outside counsel is used.
Internal NAF onboarding or branch costs: Unknown; only NAF can provide this information.
A reasonable estimate for total costs is $5,000 to $15,000 or more, depending on your net branch configuration, DBA setup, and the costs absorbed by New American Funding.
Questions to Ask New American Funding
Suggested questions:
- “Can New American Funding approve my existing DBA and add it as an Other Trade Name in NMLS for my branch?”
- “Which of my 10 target states require a branch license, branch registration, or physical branch location?”
- “Who pays the state branch licensing fees, NMLS MU3 fees, DBA filings, and MLO sponsorship transfer fees?”
- “Can my existing branch website, phone number, Google Business Profile, social media pages, and marketing assets move with me?”
- “Will my DBA appear on borrower-facing disclosures, advertising, NMLS Consumer Access, and branch pages?”
- “Can my current LOs transfer sponsorship directly from CrossCountry Mortgage to New American Funding?”
- “Are there any states where NAF will sponsor me personally but not approve my DBA or branch location?”
Conclusion
This process should be treated as a new branch setup under New American Funding, not a direct transfer from CrossCountry Mortgage. Your DBA may be reused only if you have legal control, there are no restrictions from either company, New American Funding approves it, and each state permits its use through NMLS and state regulations. For 10 states, do not rely solely on the $250 NMLS branch fee, as this is only the base MU3 processing cost. The total will likely be several thousand dollars, including state fees, DBA filings, sponsorship changes, compliance review, and company onboarding.
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If I am operating a DBA for a mortgage banker licensed in multiple states and decide to join NEXA Lending (formerly NEXA Mortgage) due to the potential income on revenue share and their goal to pay licensed loan officers residual income from servicing the mortgage loans closed, how does that work? Is it difficult to do? Does my current employer need to cancel the DBA with NMLS and the Secretary of State on each individual states licensed? What if my current employer does not release the DBA because of too much work. I heard that my current employer needs to contact each individual state’s secretary of state office and cancel the DBA and also contact the NMLS. How much would this cost me with the NMLS and each state? Are there other potential solutions of not being a DBA at NEXA BUT using my brand name and state powered or empowered by NEXA Lending. I noticed that many mortgage companies have a section on nmlsconsumer.org that says OTHER TRADE NAMES, PRIOR OTHER TRADE NAMES, PRIOR LEGAL NAMES, and websites of all independent licensed MLOs, teams, and branches? What is the easiest, fastest, and most cheapest way of using my brand name, that has been branded for many years. Thank you.
https://www.nmlsconsumeraccess.org/EntityDetails.aspx/COMPANY/1660690
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Yes, there are a few options, but the quickest and least expensive is usually not to “transfer the DBA.” In most states, a mortgage DBA or trade name is connected to the licensed company or branch, not the individual loan officer. So, if your current mortgage banker owns the DBA filing in NMLS and in each state, they handle the cancellation or changes.
The General Concept: A DBA In Mortgages Is Not the Same as Relocating a Website
In mortgage licensing, a DBA is called an “Other Trade Name” or a fake name used by the licensed company. According to NMLS, Other Trade Names include business names, fake names, official DBAs, and “doing business as” names. NMLS also says the name should be recorded and shown exactly as it appears in ads, letters, and materials sent to customers.
Consequently, Your Existing DBA Is Most Likely Affiliated With One Or Several Of The Following:Company MU1
- The overarching licensed mortgage banker’s company record.
Branch MU3
- A specific branch record associated with that company.
- State Secretary of State or fictitious-name registrations
- Certain states require DBA/fictitious-name filings at the state level, outside NMLS.
Advertising And Compliance Approvals
- Websites, email signatures, business cards, social media, and consumer-directed marketing.
- It’s not just about “can I move the DBA to NEXA?”
- The key questions are: who owns the trademark, who files the legal paperwork, and will NEXA register that trade name in the states where you want to use it if they can and want to?
Does Your Current Employer Need To Cancel The DBA?
- The answer is most likely yes if the DBA is the same one that is registered and active under your current employer’s mortgage company or branch licenses.
- If your current employer uses the DBA in NMLS, they usually have to update their NMLS record to remove the Other Trade Name from the relevant company or branch filings.
- NMLS requires that Other Trade Names be listed for the names a company uses in states that participate in NMLS, and branch Other Trade Names must be included on the Company Form.
In some states, an Advance Change Notice is required before In some states, you must give advance notice before adding, changing, or removing trade names. For example, Nevada’s checklist for mortgage banker/broker changes states that adding, changing, or removing Other Trade Names requires 30 days’ advance notice via the Company MU1 form.
The Current Employer Will Need To:
- Eliminate the DBA/Other Trade Name from NMLS.
- Revise branch records if the DBA is tied to a branch.
- Withdraw or cancel state fictitious-name filings where demand is required.
- Cease the use of the name in promotional materials.
- Possibly revise their compliance materials, signage, records, and advertising, as well as their websites.
What Happens If The Current Employer Refuses or Claims It Is Too Much Work?
- This is the problem. If your employer controls the NMLS record and state DBA filings, you probably cannot close the NMLS record yourself using your MLO account.
- You only have some influence because the employer controls the brand.
Case 1: You Personally Control the Brand Name
- If you own the trademark, domain, logo, website, and brand identity, you probably have a strong business and legal reason to ask the employer to stop using the brand after you leave.
- However, the NMLS and state records will likely stay under the company’s name, and their compliance or licensing team will need to handle any changes.
Case 2: The Employer Controls the DBA
- If the current mortgage banker filed the DBA, paid the fees, and listed it under its licenses, the regulator may see it as that company’s trade name until it is taken off.
Case 3: Ambiguous Ownership
This is the hardest situation to be in.
Before you try to move, you should have all of the following ready:
- Your DBA registration documents
- Your state fictitious-name documents
- Your domain ownership records
- Your files for the creation of the logo
- Your trademark filings, if any, and
- Your employment agreement or branch agreement
- Your records of marketing approval
- And any evidence you have that you retained brand ownership
- This is where a mortgage licensing attorney or a compliance consultant can assist you.
How Much Would it Cost?
- Unfortunately, there is no clear answer because state laws differ and control company changes, branch changes, DBA filings, cancellations, approvals for new trade names, and filings with the Secretary of State.
- However, NMLS processing fees are usually lower than state fees and the cost of handling licensing. NMLS lists fees as $120 for Company Form MU1, $25 for Branch Form MU3, $35 for Individual Form MU4, and $35 for MLO sponsorship changes per agency or license.
- But even if your NMLS fees are low, your total cost will not be. State fees, Secretary of State fees, registered agent costs, branch changes, trade-name approvals, compliance checks, legal reviews, and licensing vendor fees all add up.
- For 10 states, a realistic budget could range from a few hundred to several thousand dollars, depending on:
- How many states require separate fictitious-name filings
- Whether NEXA must add the name at the company level, branch level, or both
- Whether each state charges an amendment fee
- Whether legal or licensing vendors are necessary
- Whether the old company will do what is necessary
- Whether the name is already taken or restricted in a state
- NMLS also directs companies to use the License Requirements and Fees Chart for company and branch amendments, as well as state-specific requirements.
Can You Use Your Brand Without Being A DBA At NEXA?
- Yes, this may be the simplest solution, but it can be very complex.
- The quickest and most cost-effective way might be using your name as a marketing brand/team name rather than a legal DBA, as long as the language is approved by NEXA compliance.
Examples Are:
- Preferred Mortgage Rates Powered by NEXA Lending
- Preferred Mortgage Rates, a Mortgage Powered by NEXA Lending
- Preferred Mortgage Rates at NEXA Lending
- Preferred Mortgage Rates, Sponsored by NEXA Lending
- Preferred Mortgage Rates– NEXA Lending Branch/Team
This avoids the need to set up a formal DBA in every state right away. However, ads must clearly show the licensed company, NMLS ID, branch NMLS ID, and the individual MLO NMLS ID. Customers should not think the brand is separately licensed if it is just a marketing or team name.
Best Practical Strategy
The Most Effective Way Is Likely The Following: Option 1: Fastest and Cheapest
- Use your brand as a marketing/team brand with language-approved disclosure.
- Preferred Mortgage Rates Powered by NEXA Lending
- Licensed Mortgage Loan Originators
- NEXA Lending NMLS #1660690
- Richard Kennedy NMLS &231323
- This option is typically the faThis option is usually the fastest because you probably don’t have to wait for formal DBA approval in all the states where you want to market, as long as NEXA compliance approves the wording.
Name Under NEXA
- Request that NEXA submit your brand.
- Ask. NEXA, file your brand as an Other Trade Name in the states where they allow.
- NMLS allows unlimited Other Trade Names, but each must be filed with the correct industry and state.
- It is slower and more compliance-intensive.
Option 3: New Slightly Modified Brand Name
If your current employer won’t allow the exact DBA, change it a little to create a brand you own and that NEXA approves.
Examples:
- Preferred Mortgage Rates Group Powered by NEXA Lending
- PMR Team Powered by NEXA Lending
- Preferred Mortgage Rates Home Loans Powered by NEXA Lending
- PMR Lending Team at NEXA Lending
- This can avoid the fight over the old DBA and keep most of your brand value.
Option 4: Keep The Brand As A Media/Education Brand
You can keep the brand as an educational or media outlet and clearly state that mortgage activities are licensed separately.
Examples:
Preferred Mortgage Rates is an educational mortgage resource. Mortgage Loans are originated through NEXA Lending, NMLS #____.
This is probably a good way to use your brand on your website, forums, YouTube, and SEO materials.
What I Would Not Do
- I would not count on your old company to quickly cancel the DBA in every state.
- I also wouldn’t expect them to prove they did it.
- I would want this in writing and set a deadline.
- I would avoid promoting the brand as a mortgage lender, banker, broker, or bank branch unless you have written approval from NEXA that this wording is allowed in all states where you advertise.
Amended Step-By-Step Plan
- First, check who legally owns the brand and review DBA filings, domain names, trademarks, logo ownership, and any branch or employment agreements.
- Second, ask your current employer for a written release or written confirmation that they removed the DBA from NMLS and state records.
- Third, consult NEXA compliance/licensing, and ask if third, talk to NEXA compliance or licensing and ask if they prefer name
- Trade name for team/marketing
- “Powered by NEXA Lending” disclosure
- Branch of NEXA Lending disclosure
- No DBA, brand-name marketing only
- Finally, choose the least expensive option:
- if speed matters most, use the name as a team or marketing name.
- If long-term protection is the priority, use the name as an Other Trade Name for NEXA where needed.
- If avoiding conflicts is most important, choose a slightly changed version of the name.
The Least Expensive Option Would Be:
Use Your Brand As A Marketing Team Name Instead Of A Formal DBA, At Least For Now.
So The Name Could Be: Preferred Mortgage Rates Powered By NEXA Lending
- Next, make sure every item (websites, landing pages, business cards, social media, email signatures, and ads) clearly says that licensed mortgage work is done through NEXA Lending and includes the required NMLS IDs and state notices.
- Once you are fully set up and active, you can decide if it’s worth the time and money to have NEXA register the brand as an NMLS Other Trade Name in other states where needed.
https://www.youtube.com/watch?v=89abku6xIh0&t=367s
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This reply was modified 2 weeks, 2 days ago by Dolley.
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This reply was modified 2 weeks, 2 days ago by Dolley.
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This reply was modified 2 weeks ago by
Sapna Sharma.
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When it comes to NMLS company, branch, or individual mortgage licensing, it can get really confusing and it is very difficult to understand many questions. There are many NMLS mortgage licensing consultants and a lot of them do not return you inquiry right away. However, on NMLS mortgage licensing I highly recommend is Steven, the owner and President of Integrity Mortgage Licensing. When I was sponsored by my previous employer, Loan Cabin, Inc., Integrity Mortgage Licensing was the company’s NMLS mortgage licensing consultant. I had nothing but phenomenal experience with Steve and his staff at Integrity Mortgage Licensing. Plus, I highly recommend Integrity Mortgage Licensing’s website. The website is very informative, user-friendly, and easy to navigate. Most questions you have should be on their website. However, if you need to get a hold of someone, you can call them and if they do not answer, they will return your call promptly. Attached is the link to Integrity Mortgage Licensing.
Integrity Mortgage Licensing – State Mortgage License Service
integritymortgagelicensing.com
Integrity Mortgage Licensing - State Mortgage License Service
Mortgage Company Licensing Services We Assist Mortgage Companies We are a State Mortgage Licensing Service We assist mortgage companies with obtaining Mortgage Broker Licensing, Mortgage Lender Licensing and Banker Licensing,
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