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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.
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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States With Distance Requirements From MLO Home to Licensed Branch
By Gustan Cho, NMLS 873293, National Managing Director of Coast 2 Coast Mortgage Lending, LLC dba Gustan Cho Associates NMLS 376205.
No single national rule governs mortgage loan originators working from home. Some states set a specific distance, often between 50 and 100 miles from the licensed branch, while others measure by commute time. Meanwhile, several states have dropped distance requirements altogether, shifting their focus to licensing, branch oversight, and data security for remote mortgage origination.
Why this is Important for Multi-State MLOs
Having an MLO license in a state does not guarantee you can work remotely there. Many regulators now tie remote work eligibility to how far an MLO’s home is from a licensed branch, or whether there is an approved remote work policy in place. At Gustan Cho Associates, with operations in 48 states and D.C., we closely review branch locations, remote-work eligibility, and supervisory protocols for our loan officers.
For companies with mortgage originators across several states, knowing each state’s distance requirements is essential before assigning remote work locations. This helps keep both the MLO’s license and the company’s sponsorship in good standing.
Distance vs. Branch Requirements: What’s The Difference
Exploring these concepts one at a time makes the differences much clearer. A branch license authorizes a business location to conduct licensed mortgage activities, but does not permit individuals to work from any location. An MLO license allows an individual to originate loans, but does not automatically permit work from any site.
Certain states set strict limits on how far an MLO’s home or business can be from the supervising licensed branch, using either mileage caps or commute times.
Others skip distance rules entirely and instead require a written remote business policy that addresses consumer protection, supervision, and cybersecurity. In short, even a fully licensed MLO can fall out of compliance if their work location does not meet state distance, branch, or remote work requirements.
States With A Distanced or Time-Based Rule
The following list draws on insights from licensing consultants and industry data as of mid-2026. Use it as a starting point, not a final compliance guide. State laws and remote work policies shift often, and many details still await official confirmation from regulators.
- In Alabama, an MLO must be within approximately 60 miles of their branch, though this may be extended with an approved remote work policy.
- Connecticut’s rule is unclear; the distance is about 100 miles, and it is uncertain if any temporary remote work allowance remains in effect.
- Kentucky also uses a 60-mile distance.
- Louisiana may have a 120-mile limit, but this is unconfirmed and cannot be used in filings until the regulator responds.
- Mississippi sets a distance limit of roughly 125 miles, though it is unclear if this is measured from the MLO’s home, workplace, or the licensed branch.
- When planning branch locations for a dispersed team, the distance from the branch to the workplace becomes crucial.
- Nebraska swaps mileage for commute time, allowing a 2-hour trip to the sponsoring office.
- In New Jersey, a 2.5-hour commute is permitted, and loan officers must be classified as either W-2 or 1099, not both.
- New Mexico requires a minimum distance of 75 miles.
- In New York, the rule may be either a 50-mile limit or a 2-hour travel time, depending on the license type.
- South Carolina’s situation is more complex, with two regulators each applying a 75-mile distance, and the rule depends on the license type.
- Wisconsin and Wyoming both set a 100-mile distance requirement.
With Unclear or Transitional Remote-Work Status
Some states lack confirmed distance-work regulations, and their remote-work status has shifted dramatically in recent years.
- Alaska might have permitted work-from-home arrangements, but this remains unconfirmed.
- In 2022, Maine issued some remote work permits, but those were not renewed, so the original in-branch requirements could return.
- South Dakota’s branch permits for work-from-home have expired, leaving it unclear if a branch permit is now needed.
- Vermont is heading toward broader remote work, but a formal rule has yet to be finalized.
- For these four states, always secure written confirmation from the state regulator before approving any remote work assignment. Never rely solely on call center information for compliance decisions.
The Broader Trend: States Moving Away From Distance Rules
Most states are shifting away from strict mileage limits. Illinois, Virginia, Florida, Nevada, and Montana once had permanent remote-work laws with distance requirements, but now emphasize supervision, security, recordkeeping, advertising compliance, and consumer protection. Under these rules, MLOs can work remotely as long as certain records are not kept at the remote site, client meetings happen only at licensed locations, and the remote site is not used as a real estate broker’s office.
Out of 53 U.S. jurisdictions tracked by the Mortgage Bankers Association—including D.C., Guam, and Puerto Rico—about 30 have permanent remote work laws, and 9 have temporary rules.
This means most places now allow some form of remote work, though the details can vary greatly. Starting September 20, 2025, the NMLS will introduce a formal work-from-home status for MLO records. Companies will need to assign this status for new hires and update it for current MLOs before the 2026 renewals. If the remote status does not align with state licensing rules, regulators could take enforcement action, posing a compliance risk.
Gustan Cho Associates Multi-State Branch Strategy.
When considering a new branch or remote role for a loan officer, we match the states where our MLOs live with those where they hold licenses. We pay extra attention to states with unclear distance rules or unsettled remote work policies, since these carry the highest compliance risks. We never choose branch locations just because of low state filing fees.
We weigh where our loan officers are based, which states have strong loan volume, compliance with distance rules, supervisory needs, growth strategies, and how well a branch can serve MLOs in nearby states.
Even the best-located branches can be limited by office, supervision, or distance rules, so we routinely review each state’s requirements. We never finalize remote work assignments or branch applications without obtaining official written clarification from the state regulator when distance or remote work rules are unclear. While call center responses can offer initial guidance, they do not count as formal compliance confirmation.
Nationwide NMLS Rule for Mortgage Loan Originators Working Remotely
Is there a nationwide rule for mortgage loan originators working remotely? No single nationwide rule exists. Many states impose distance requirements, while others do not. Some use commute standards, and others rely exclusively on remote work policies.
What Does the State MLO Distance Requirement Look Like?
- Distance requirements typically range from 50 to 100 miles from a licensed branch.
- Certain states, such as Nebraska and New Jersey, use commute time instead of mileage.
Will an MLO License Let Me Work Remotely in That State?
- Not directly.
- An MLO license authorizes loan origination but does not permit work from any location.
- In some cases, an MLO may work from home if the residence is a licensed or registered branch, or if the company has an approved remote work policy.
Can a Home Address Be a Licensed Branch?
- Yes, in certain circumstances.
- If a home is licensed as a branch in one state, it may also be licensed as a branch in other states.
- Confirmation from each state regulator is required for work-from-home arrangements.
What Does the State Do if a Company Mislabels an MLO’s Remote Work Status on NMLS?
- If an MLO’s remote work status is inaccurately reported on NMLS, the state regulator may take compliance action against the company.
- After September 2025, NMLS filings will be treated as compliance matters rather than only administrative records.
Which States Have Moved Away from Distance Requirements Entirely?
- Illinois, Virginia, Florida, Nevada, and Montana have enacted permanent remote-work laws that prioritize supervision, consumer protection, cybersecurity, and recordkeeping rather than distance requirements.
- Consult the NMLS State Resource Center and the License Requirements and Fees Chart, and contact the state regulator directly.
- NMLS Consumer Access is also a reliable public source for company, branch, and individual license information.
- No national standard sets the allowed distance between a mortgage loan originator’s home or workplace and a licensed branch.
- Where such rules exist, they usually fall between 50 and 100 miles, though some states use commute time instead.
- Many states have dropped distance rules, focusing instead on supervision and security.
- Because state regulations change often, companies should always check with each state regulator before making decisions about branch licensing or MLO placement.
https://www.nmlsconsumeraccess.org/
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