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States with Distance Requirements from MLO Home to Licensed Branch
States With Acceptable Distance Between MLO Residence and Licensed Branch
By August 1, 2026, it is expected that even fewer states will have clear rules about distance requirements for mortgage licensing.
The Nationwide Multistate Licensing System (NMLS) does not have a national rule about distance. Each state’s regulators decide if a mortgage loan originator (MLO) can work remotely and set their own supervision rules. NMLS asks companies to report whether an MLO works in an office, is partly remote, or is fully remote, and where supervision occurs. Companies must follow the licensing and remote work rules for each state.
States With a Justifiable Current Distance or Commuting Requirement
Wisconsin: 100 Mile Requirement
Wisconsin is notable for having a clear and simple distance rule.
An MLO Licensed in Wisconsin and Working for a Company:
- Has a branch licensed at his or her residence; or
- Works in a licensed or registered company office that is within 100 miles of the MLO’s residence.
- This rule also covers remote work.
- If the assigned office is over 100 miles from the MLO’s home, Wisconsin requires the home to be licensed as a branch office (DFI).
- Classification: Confirmed Hard Mileage Limit.
<hr>Wyoming: 100 Mile Requirement
- According to the current NMLS MLO application checklist for Wyoming, people who live more than 100 miles from a licensed site do not meet the location rule.
- The checklist also says an MLO can license their home if needed.
Idaho: Reasonable Commuting Distance
- Idaho does not set a specific mileage limit.
- Instead, an MLO’s work location must be within a reasonable travel distance from their home.
Because There is No Set Commuting Distance
Companies Should Consider These Factors:
- Actual driving time
- Road and weather conditions
- If the MLO has to report to the office regularly
- How the MLO is supervised
- If the reported office is a real, functioning office
- Idaho does not require licensed companies to have a physical office in the state.
- However, the MLO must be supported by and connected to an Idaho-licensed location.
- Classification: Confirmed qualitative commuting standard.
Vermont: Reasonable Commuting Distance for Mortgage-Broker MLOs
Vermont regulations require that a Mortgage Broker’s MLO must:
- Be assigned to a licensed location; and
- Reside within a reasonable commuting distance of that location.
Vermont does not set a specific mileage or drive-time limit for this rule. The regulation also prevents MLOs from advertising, using business cards, or sending offers or letters that show an unlicensed home address.
Because Vermont’s remote work rules are flexible, companies should get written approval from the Department of Financial Regulation if an MLO lives far from their assigned branch.
Classification: Confirmed qualitative standard, particularly for mortgage-broker MLOs.
State With a Conditional 100-Mile Rule
New Hampshire: 100 Miles When Remote Address Is Publicly Known
- New Hampshire does not require every remote MLO to live within 100 miles of a branch.
Remote Work from an Unlicensed Home or Other Location is Allowed When:
- The location is not disclosed or shown to the public as a mortgage office;
- Consumers do not come to the location;
- There is no face-to-face mortgage business conducted at the location;
- The consumer information and business records are adequately safeguarded, and
- The MLO is under the oversight of the sponsoring company.
- If a remote location is listed in a phone book, on business cards, or on letterhead, the New Hampshire supervisory office must be within 100 miles.
- Otherwise, that remote site probably needs its own license.
- The 100-mile rule depends on how and where the location is shown, not just the distance from home to branch.
Nebraska Should Be Verified at a Minimum
- Many compliance sources state that Nebraska expects a ‘commutable distance,’ typically defined as a two-hour drive each way.
- Always check the latest Nebraska rules, NBDF FAQs, or NMLS checklists to confirm if this two-hour rule is official.
Nebraska’s Status Can Be Summarized as Follows:
- Reported regulator or examiner practice—written confirmation required.
- Firms should not refuse sponsorship or avoid opening a branch just because of the commonly mentioned two-hour limit, unless the Nebraska Department of Banking and Finance has issued a recent official statement.
- The old 125-mile rule no longer applies.
Mississippi
- Mississippi’s former rule required an MLO to be assigned to a licensed location that is within 125 miles of the MLO’s residence.
- Senate Bill 2508 removed this rule starting July 1, 2025.
- Mississippi now allows remote work if proper supervision, information security, and control measures are in place, there is no in-person consumer contact at the work home, and physical mortgage records are not kept there.
- Do Not List Mississippi as a Current 125-Mile State.
- Former 100-Mile Rule Was Eliminated.
Pennsylvania’s Former 100-Mile Rule Was Removed
- The law was amended to replace that restriction with authorization to work from a qualifying “remote location” under specified supervision, security, advertising, recordkeeping, and consumer-contact conditions.
- Do not list Pennsylvania as a current 100-mile state.
Pennsylvania
- Previously, Pennsylvania required an MLO to be at their home or a licensed company location within 100 miles.
- The law has changed, so now MLOs can work from a qualifying “remote location” as long as they follow the supervision, control, security, advertising, recordkeeping, and consumer contact rules.
New Mexico’s 75 Miles Is a Historical Standard
- The New Mexico Financial Institutions Division says that before the COVID-19 Public Health Emergency,
- 75 miles was considered an acceptable commuting distance to a licensed branch.
- New Mexico’s 2020 Remote Work guidance is still in effect, with no plans to cancel it.
- The agency also advises companies to have a backup plan in case the guidance changes.
- The old 75-mile standard is currently suspended under ongoing telework guidance.
- This is not a current unconditional mileage limit.
- Classification: Historical 75-mile standard suspended under continuing telework guidance—not a current unconditional mileage cap.
South Carolina 75-Mile Provision is Not a Maximum Distance Rule
- South Carolina law lets a regulator license an MLO’s home as a branch if the home is more than 75 miles from a commercial branch office.
- This rule does not require every MLO to live within 75 miles of a branch.
- Instead, it allows a home to be licensed as a branch if the MLO lives farther away.
- Different laws apply to mortgage brokers and lenders.
- Do Not Describe South Carolina Simply as a “75-Mile Maximum” State.
North Carolina’s Old 90-Mile Information Is Outdated
- Earlier compliance sources mentioned a 90-mile commuting rule in North Carolina.
- According to the current North Carolina Commissioner of Banks FAQ, an MLO can work from home if the home is not registered as the company’s main or branch office and is not used to store company records.
Illinois Has No Commute-Distance Requirement
- Illinois does not have a distance rule for MLO commuting.
- The sponsoring company is responsible for supervising the MLO and is accountable for their actions.
Current Working Compliance List
For a Conservative Company Licensing Matrix, I Would Use the Following Classifications:General Distance or Commuting Requirement
- Wisconsin — 100 miles
- Wyoming — 100 miles
- Idaho — reasonable commuting distance
- Vermont — reasonable commuting distance for mortgage-broker MLOs
Conditional Rule
- New Hampshire — 100 miles when the remote address is publicly identified in specified materials
- Written regulator confirmation recommended
- Nebraska — reported commutable-distance or two-hour practice, but no sufficiently clear current public authority located
Do Not Use as Current Blanket Limits
- Mississippi — former 125-mile rule removed
- Pennsylvania — former 100-mile rule removed
- New Mexico — historical 75-mile standard; telework guidance remains in effect
- South Carolina — 75 miles concerns eligibility to license a residence as a branch
- North Carolina — old 90-mile information superseded by current remote-work guidance
- Illinois — expressly has no commute-distance requirement
Do Not Use This as a Current Blanket Limit.
The Former 125 Mile Rule Has Been Eliminated
- Pennsylvania: The former 100-mile rule has been eliminated
- New Mexico: Former 75-mile rule; guidance on telework still applies
- South Carolina: 75 miles is a concern only when granting a license to operate a branch from a residence.
- The old 90-mile rule is now superseded by the current guidance on telework
- Illinois clearly has no commute-distance rule.
Key Compliance Recommendations
When Assigning a Remote MLO to a Distant Branch, Companies Should Keep the Following Documents:
- the current state of the MLO checklist,
- the state’s remote work guidance,
- the MLO’s home and actual work addresses,
- the branch in NMLS that the MLO is to supervise,
- written confirmation from the regulator for any questionable commute, and
- the company’s policies on supervision, cybersecurity, record keeping, advertising, consumer meetings, and disclosure of addresses.
Main: Keeping the above information is required to comply with NMLS remote work reporting rules. State law about remote work is more important than NMLS reporting. Regulators may investigate or take action if reported remote work does not comply with state licensing rules. This document is regulatory research, not legal advice. If a home is near or over a commuting limit, the state authority should make the final decision,
dfi.wi.gov
DFI Mortgage Banking Frequently Asked Questions
DFI Mortgage Banking Frequently Asked Questions
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