The Impact of Late Credit Banking

Several states had a deadline for MLOs to complete their testing and education requirements by June 30th.  This morning NMLS received a report that an MLO had their licensed suspended by a state regulator because the individual’s record did not show they had completed pre-licensure education.  As a result, the individual lost a day of work. The problem is that the individual did complete their education on June 16th, however, the course provider did not complete the credit banking until July 1, nearly a week after the 7 day required window.  If the credit banking had been reported on time, the individual would not have had their license suspended.

To comply with the SAFE Act, many states have a July 31 deadline for new MLO’s to complete pre-licensure and/or testing requirements.  As we transition through the rest of the summer and into the fall there are additional deadlines, and then in November and December many states will have a requirement for MLOs to complete continuing education by year end.   As the case above demonstrates, late credit banking is a very serious problem that can adversely impact an individual’s livelihood.  All providers are reminded that they are responsible for reporting course completions to NMLS within 7 calendar days from the scheduled course end date. Detailed instruction on how to credit banking using either the “submit” or “upload” process can be found in the User Guide: Reporting of NMLS Approved Course Completions (Credit Banking) which is available in the NMLS Resource Center. If you encounter a problem with credit banking please contact Alan Ridenour ( as soon as possible.

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