Criminal Background Check  

Prior to registration, mortgage loan originators (MLOs) must submit fingerprints to NMLS (unless they already have fingerprints on file with NMLS) and authorize NMLS to process a criminal background check (CBC) with the FBI.  The results of the CBC are returned to the employing institution through NMLS. 

 

Step 1: Will the institution submit the Criminal Background Check authorization on behalf of the individual MLOs?

Any individual who meets the definition of a mortgage loan originator and must be registered on NMLS is required to have a Federal CBC processed with the FBI.

In addition to initial registration, an individual will also need a new CBC when making an employment change. See the Changing Employers Quick Guide for instructions on this process.

 

Step 2: Authorizing a Criminal Background Check Request

A CBC authorization must be completed prior to scheduling a fingerprint appointment. This authorization is processed through the MU4R filing on NMLS.

In order to determine the best method of authorizing a CBC request, an individual should consult with their institution to identify who will be submitting the CBC authorization via the MU4R. The following two options are available:

  • An individual will complete and submit the MU4R form: See the Submitting Your MU4R: MLO Initiated Quick Guide.
  • The institution will initiate and submit the MU4R on behalf of an individual: See the MU4R Attestation Quick Guide.

 

Step 3: Scheduling a fingerprint appointment via Fieldprint

Once an individual or employer has paid for the CBC request through NMLS, the MLO will be able to schedule a fingerprint appointment. Go to Schedule a Fingerprint.

NMLS has developed the following options for submitting fingerprints:

1. Submit New Prints via fingerprinting vendor, Fieldprint.

NMLS has developed a nationwide network of approved live scan and paper card fingerprint sites, administered by NMLS’ fingerprinting vendor, Fieldprint. After providing necessary demographic information, authorizing and paying for the background check in NMLS, MLOs are directed to the Fieldprint scheduling site to schedule an appointment at one of over 700 live scan locations where fingerprints can be captured and submitted electronically. If none of these sites are geographically convenient to an MLO, a visit can be scheduled at one of more than 6,000 local police departments where fingerprints can be taken on cards provided to the MLO by Fieldprint and then mailed to Fieldprint for scanning and submission to NMLS. See Livescan Locations.

NOTE: After authorizing a new CBC and selecting to submit new fingerprints, fingerprints must be taken within 180 days.  If fingerprints are not submitted within 180 days, the background check window will expire and a new CBC will need to be authorized and fees paid.

2. Use existing fingerprints already on file with NMLS.

If an individual has held a state license or federal registration in the past year, it is possible that NMLS already has fingerprints on file and new prints do not need to be submitted. The election of “Use Existing Prints” can be made via the MU4R to conduct a CBC for the purpose of federal registration.

Note: The option to use existing prints will only be available if the fingerprint records on file are less than 3 years old. Due to FBI rules, individuals will need to provide new fingerprints when requesting a new CBC if previously submitted fingerprints are more than 3 years old.

3. Use existing equipment or network to establish a connection to NMLS directly.

NMLS recognizes that some institutions may have existing systems for fingerprint collections and a volume that makes it worthwhile to establish a direct connection. Due to the technical and legal requirements necessary to facilitate such an alternative fingerprint submission process, NMLS can only offer this option under the conditions listed below. If, after reviewing these conditions, your institution is interested in using existing fingerprint files collected outside of the NMLS network, please contact Fieldprint at 1-877-614-4365. Conditions are as follows:

a.     Execution of a legal agreement between the institution and Fieldprint, approved by State Regulatory Registry LLC
In order to protect the integrity of fingerprints collected and maintained by NMLS, SRR requires certain quality controls be in place as institutions collect fingerprints that mirror those in place in the NMLS network. To ensure the required controls are in place and the agreement is consistent across participating institutions, the standard agreement cannot be adjusted. 

b.    Adherence to the Interface Control document
Fieldprint has developed an interface control document for the submission of existing fingerprints to NMLS. This document regulates submission of fingerprints and helps ensure that submitted fingerprints are connected with the correct mortgage loan originator’s record in NMLS. Institutions interested in submitting existing fingerprints or using its vendor to collect fingerprints for submission to NMLS must abide with the technical and policy requirements outlined in this document to ensure a uniform standard of all fingerprints collected by NMLS.

c.     Institution must have a minimum of 1,500 MLOs registered in NMLS
Due to the costs associated with establishing monitoring, and maintaining this alternative submission process, SRR believes that the alternative process is only effective for institutions with a high volume of prints to process. As such, institutions must have a minimum of 1,500 MLOs registered in NMLS in order to participate in this alternative process.

d.     The Institution’s fingerprint acquisition vendor must be an FBI approved channeler
To ensure the institution’s selected vendor meets minimum information security and auditing requirements, the vendor providing fingerprint acquisition and management services to the institution must be an FBI approved channeler. List of FBI approved channelers

NOTE: All submissions must be completed through one connection.  Institutions are responsible for the consolidation and management of prints from multiple livescan terminals.

4. Schedule an onsite group appointment for a large number of individuals in a single location.

Fieldprint can arrange an onsite visit to accommodate large groups of MLOs for a fee to cover travel and set-up. While it can be arranged for any size group, this typically makes sense if an institution has 30 or more MLOs to have fingerprinted at one time. For more information regarding onsite group appointments, see Group Fingerprint Appointments.

Please note that regardless of the submission method, fingerprints cannot be submitted to the Federal Registry until the MLO’s MU4R has been submitted and all appropriate fees have been paid.

 

Step 4: Viewing CBC Status and Results

Fingerprints are automatically processed with results reported back to NMLS from the FBI, usually within 48 hours of submission. Some exceptions to this may occur if an individual has been sent to Name Check processing where results may not be returned from the FBI for up to 90 days.

To view your employee’s CBC status and results see  View CBC Status Quick Guide.

To help you determine what step your employee is on within the CBC process, please see the Fingerprint Status Reference Chart below:
 

Fingerprint Status Reference Chart

Fingerprint Status in Composite View

Action Required by MLO?

Pending Fingerprint

Yes, an individual needs to schedule through the Fieldprint website to have fingerprints taken.

Processing Fingerprints

No action is needed from individual.
A CBC request has been submitted, prints have been taken. The background check is being performed.

Processing Name Check

No action is needed from individual.
A background check is being performed using the “Name
Check” method.

Expired

Yes, if a CBC is required an individual needs to authorize a new CBC again via the MU4R in order to schedule a fingerprint appointment or fingerprints were not taken within the 180 day allotted time.

Closed but the "Reason Closed" field shows illegible

Yes, a new CBC must be authorized via the MU4R in order to schedule a fingerprint appointment again. Payment is not required during CBC authorization.
Prints were categorized as illegible by the FBI.

Closed but the "Reason Closed" field shows received

No action needed from the individual.
Process is complete.

Note: If the FBI determines that the prints are illegible, you will receive a system notification and individual will be required to authorize a new CBC.

 

Fees

 

Live Scan
(electronic)                           $36.25  CBC Processing Fee

OR

Paper Card Capture*
(if Live Scan is not selected)  $36.25  CBC Processing Fee
                                           $10.00  Card Packet Fee
                                           $46.25  Total

*Paper Card Capture costs more due to the manual processing of fingerprints. For more details see Electronic vs Paper.

 

Refund Policy

Payments collected through the NMLS are non-refundable.

 

FBI Privacy Act


FBI-Required Privacy Act Statement