Disciplinary Actions 

To fulfill the requirements of the Consumer Financial Protection Bureau’s (CFPB’s)Regulation G,  the NMLS Federal Registry collects  information regarding disciplinary actions covered by the disclosure questions that individual mortgage loan originators (MLOs) are required to complete, and update as necessary, as part of the SAFE Act’s federal registration process.

MLOs who have answered “Yes” to at least one disclosure question, and the institutions that employ them, should read through this information to understand what information is required and what information will be made public.  Most MLOs have answered “No” to all disclosure questions, so the information and requirements below will not apply to them them. 

What are Disciplinary Actions? 
Disciplinary Actions are those final, adjudicated actions covered by the MU4R’s disclosure questions.  MLOs who answer “Yes” to any disclosure question on the Form MU4R are required, as part of the MU4R submission process, to complete the Disciplinary Action section for each “Yes” response. 

Why must MLOs provide this information to NMLS?
Information regarding these Disciplinary Actions is required at the direction of the Consumer Financial Protection Bureau’s (CFPB’s) direction.  Please see the  CFPB’s Communication on Disciplinary Actions for additional information.

What information must be provided?
MLOs will be required to provide the following information for disciplinary actions that necessitate a “Yes” response to the MU4R disclosure questions:

  • Action Type (Criminal, Regulatory, Civil Judicial, or Civil Regulatory)
  • Name of Authority that took the Action being disclosed
  • Date of Action
  • Official Documentation related to the Action (e.g., court order or letter from regulatory authority), to be uploaded as a PDF file

Additionally, the MLO will have the option to provide an explanation of the disciplinary action, in his or her own words.  This MLO-provided explanation is not required.

The Disciplinary Action Reference Guide provides a step-by-step explanation for completing this process.

Will any of this information be made public?
Yes.  Beginning on March 18, 2013, the following fields will be displayed in NMLS Consumer Access:

  • Action Type (Criminal, Regulatory, Civil Judicial, or Civil Regulatory)
  • Name of Authority that took the Action being disclosed Date of Action
  • Official Documentation related to the Action (e.g., court order or letter from regulatory authority), to be uploaded as a PDF file
  • MLO’s explanation of the action, if the MLO chooses to provide one


If an MLO has answered “No” to the disclosure questions, is anything required?
No.  MLOs that responded “No” to all disclosure questions do not need to complete any new sections, and do not need to update their records for this purpose.  Most MLOs have answered “No” to all disclosure questions.

How can institutions manage this process?
The MU4R Detail Report  provides institutions with an efficient way to determine which actively registered MLOs currently have “Yes” responses to any Disclosure Question and if they have provided the required Disciplinary Action information:

  • Column AI of the MU4R Detail Report (“Disclosure Questions "Yes" Responses?”) will display a “Y” for any MLO who has answered “Yes” to at least one disclosure question.  These MLOs are required to also complete the Disciplinary Action information.
  • Column AJ of the MU4R Detail report (“Disciplinary Actions Exist?”) will be populated with a “Y” for any MLO who has completed the Disciplinary Action section.  If an MLO has responded “Yes” to a disclosure question but has no Disciplinary Action information, he or she will need to file an updated MU4R with this information as soon as possible.

Institutions can also use the MU4R Detail Report to determine when the most recent Form MU4R was submitted (specifically, Column AU).  See the Resource Center’s Reports page for more information regarding the MU4R Detail Report, including field definitions and a sample report.

Institutions can initiate MU4R amendments for their MLOs, but the individual MLO will always need to log in to NMLS and attest to the amendment before it is considered formally submitted..  See the “Amending MLO Information” section of the Manage MLO Registration Navigation Guide.

Who should I contact with questions?
Individuals and Institutions can refer to the  CFPB’s Communication on Disciplinary Actions.  Any inquiries regarding the interpretation of disclosure questions or disciplinary action requirements should be directed to the CFPB: CFPB_SAFEAct_Inquiries@cfpb.gov.

Any inquiries regarding the functionality itself should be directed to the NMLS Call Center 1-855-NMLS-123 (1-855-665-7123)

[1] 12 CFR 1007.103(d)(1)(iii)-(viii)