By
Knowledge Coop
•
August 24, 2026
NMLS revised its individual disclosure questions for MU2 individuals and state-licensed MU4 mortgage loan originators (MLOs) on April 18, 2026.
The updated questions apply retroactively, meaning affected individuals need to review and answer the revised questions even if they previously completed their NMLS disclosures.
NMLS strongly encourages licensees and companies to complete the revised disclosure questions by August 31, 2026. The August 31 date is not a statutory deadline, but completing the update by then gives regulators time to review changes before NMLS renewal season.
For MLOs, control persons, branch managers, qualifying individuals, and mortgage companies, taking care of the update now can also help prevent incomplete disclosures from delaying future NMLS filings.
The NMLS disclosure questions are part of the forms individuals and companies use to provide licensing information to state regulators.
The effort to revise these questions began in 2020, when regulators initiated a holistic review. Feedback from regulators and public comment periods helped identify questions and terminology that needed clarification.
The revised NMLS disclosure questions are intended to:
The changes officially took effect on April 18, 2026.
The revised disclosure questions apply to all MU2 individuals and state-licensed MU4 MLOs.
This includes individuals who previously answered the former versions of the questions. NMLS instructs affected individuals to review the revised questions as though they are answering them for the first time.
For mortgage companies, the update is especially important because MU2 individuals are associated with company and branch filings.
The 2026 NMLS disclosure question update includes several changes to how questions are written, organized, and defined.
Key changes include:
Because the wording and definitions have changed, MLOs should not assume that an answer provided under the previous questions will remain the same.
August 31, 2026, is a strongly recommended completion date, not a statutory deadline for all licensees.
NMLS is encouraging the industry to complete the revised disclosure questions by August 31 so state regulators have sufficient time to review updated responses before the 2026 NMLS renewal season.
That distinction matters. While missing August 31 does not automatically mean an MLO has missed a licensing deadline, waiting can create complications as renewal activity increases.
Yes. Associated MU2 individuals generally need to complete and attest to the revised disclosure questions before a company can submit the related MU1 or MU3 filing.
That makes this more than an individual housekeeping task.
Mortgage companies should identify MU2 individuals who still need to complete their revised disclosures and give them enough time to review, answer, and attest to the questions before upcoming company or branch filings.
Agencies may also require completion of the revised questions before approving certain pending or new license applications.
Yes. The revised questions apply retroactively.
NMLS advises individuals to approach the revised questions as though they are answering them for the first time. That means reviewing the new wording and definitions rather than assuming a previous "Yes" or "No" response still applies.
Previous disclosure answers and explanations remain available in NMLS for reference.
If an existing explanation needs to change, or an answer changes from "No" to "Yes," NMLS recommends explaining the reason for the change at the beginning of the supporting document. This can help regulators understand and review the updated response.
State-licensed MLOs who have not completed the revised MU4 disclosure questions should log in to NMLS and review their filing as soon as possible.
Before submitting, carefully read the revised questions and definitions. Pay particular attention to questions involving regulatory actions, criminal history, civil judicial actions, financial services, and other areas where terminology has changed.
Companies should also check the status of their MU2 individuals and make sure required attestations are completed before attempting related MU1 or MU3 filings.
If you're unsure how a disclosure question applies to your specific circumstances, consider consulting your company's compliance or legal team before submitting your response.
The revised individual disclosure questions took effect on April 18, 2026.
The revised questions apply to all MU2 individuals and state-licensed MU4 mortgage loan originators.
Yes. Individuals who previously completed the former disclosure questions still need to review and answer the revised questions.
NMLS strongly encourages completion by August 31, 2026 so regulators have time to review changes before renewal season.
No. August 31 is a recommended target for completing the revised disclosure questions, not a universal statutory renewal deadline.
An associated company may be unable to submit its related MU1 or MU3 filing until required MU2 individuals have completed and attested to the revised disclosure questions.
NMLS provides an official Disclosure Questions Update resource and an Industry FAQ explaining the revised questions, implementation process, and recommendations.
Here is the full disclosure questions update and FAQs.
The 2026 NMLS disclosure question update affects all MU2 individuals and state-licensed MU4 MLOs, including people who previously completed their disclosures.
The revised questions have been in effect since April 18, 2026, and NMLS strongly encourages completion by August 31, 2026.
Getting ahead of the August 31 target gives regulators more time to review changes before renewal season and helps companies avoid incomplete MU2 attestations interfering with MU1 or MU3 filings.
For mortgage professionals, the best move is straightforward: review your revised NMLS disclosure questions now instead of waiting for renewal season.
