New fingerprints required on a newly hired MLO?

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Question:

We have a new employee who was registered as an MLO at another financial institution. Upon updating their NMLS registration for our employment, we learned their fingerprints are over 3 years old. Can they still originate loans with us?

Answer:

No, not yet. They are forbidden from acting as your MLO (which includes mortgage loan origination) until they have satisfied all NMLSR registration requirements. The NMLSR requires new fingerprints after three years if the MLO changes employers. There will likely be some unhappiness over this, but that matter is outside of your control. What IS in your control is limiting that new employee’s activities until fingerprints are complete and satisfactory results received.