I would be listing them on the naughty list and they are going to have to refrain from any MLO activity until their reactivation is completed.
If the renewal process is not completed prior to December 31st, the MLO is placed in an “Inactive” registration status both on NMLS and NMLS Consumer Access. Inactive registrations must be reactivated in order to have an “Active” registration status.
NMLS requires a $30 processing fee for each MLO seeking to renew or reactivate a registration. MLOs who are submitted for renewal but did not complete renewal attestation prior to December 31 need to be reactivated, incurring an additional $30 processing fee at the time of reactivation.
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