NMLS Continuing Education Cheating Schemes Under Investigation

December 20th, 2021 by Sean A. Stephens, Esq., CMB®

NMLS Continuing Education Cheating Schemes Under Investigation

There is an on-going federal investigation being conducted by the Conference of State Banks Supervisors Non-Depository Supervisory Committee (CSBS). The CSBS is the national organization for state financial regulators in all 50 states, District of Columbia and U.S. territories.  The NMLS system was created in part by the CSBS.

Mortgage Loan Originators (“MLOs”) need to be aware of fraudulent continuing education (“CE”) schemes which involve NMLS approved CE providers who work in concert with the MLO seeking the CE credit hours. This involves the MLO signing up for classes with a particular approved CE provider with the intent to gain the required CE credit, despite not actually completing the actual classes.

This is especially important for state licensed MLOs who are seeking to meet continuing education requirements since the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (“SAFE Act”) requires that these MLOs meet both pre-licensure as well as annual CE requirements.

NMLS Cheating Investigation

It is good practice for mortgage lenders to document their MLO CE policy and whether they require their MLOs to independently maintain their NMLS continuing education.

If you have been contacted with respect to this on-going investigation or have additional concerns, please contact your counsel to discuss further.


Sean A. Stephens, Esq., CMB® 

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