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MLO Transfers to Location: Updating Address

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If an MLO transfers to another location at the same institution or there is a change in the address of the location that the MLO directly reports to, how long does the MLO have to update the contact address on the NMLS consumer access site to reflect the (new) accurate address location? I couldn't find anything specific regarding a time frame within the regulation, and it only touched on the requirement of internally auditing, at minimum, annually to ensure accuracy.

There isn't anything specific in the regulation. There are some changes (related to legal cases, regulatory enforcement actions, etc.) that the MLO is required to update within 30 days. But as to other information, including the address that's the MLO's principal business location, the bank is required to have policies and procedures designed to review that information (frequency not stated) and compare it with its records. Theoretically, that can occur annually prior to the two-month renewal window.

It's up to the bank to decide how frequently those checks are done.

First published on 09/15/2019

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