December 31 is the end of the window, not your deadline

NMLS accepts annual renewal filings from November 1 to December 31. Treating December 31 as the deadline is the mistake, because it is the end of a system's window rather than a date any particular regulator set.

Eight states set the MLO renewal deadline at December 1. Georgia does the same by rule. Illinois wants the filing in 30 days before expiry. Washington says December 15, and West Virginia says November 2. Fourteen state agencies offer no reinstatement at all once the year turns, and seven of the rest close earlier than the end of February, Ohio on February 14.

A missed renewal also means two unrelated things depending on who the originator is. If they are registered at a depository, the consequence is reversible, has no end date, and is not written in any regulation. If they are state-licensed, a statute expires the licence and starts a clock that ends in reapplying from scratch.

The two lanes, and why the contrast matters

Most rosters carry both kinds of people, and most renewal guidance silently addresses only one.

Registered originators: no regulation says what happens

An originator at a depository institution is registered, not licensed. The duty is statutory. 12 U.S.C. § 5103(a) says an individual may not originate without

obtaining, and maintaining annually ... a registration as a registered loan originator

and Regulation G carries it into the renewal period. 12 CFR 1007.103(b)(1) requires the registrant to

renew the registration during the annual renewal period, confirming the responses set forth in paragraphs (d)(1)(i) through (viii) of this section remain accurate and complete, and updating this information, as appropriate

What neither the statute nor the regulation contains is a consequence. A full-text read of 12 CFR Part 1007, all five sections, finds zero occurrences of inactive, lapse, expire, reactivate, reinstate, terminate, status or grace. The one legal consequence stated anywhere in the part is at 1007.103(a)(1):

Any such employee who is not in compliance with the registration and unique identifier requirements set forth in this part is in violation of the S.A.F.E. Act and this part.

So the status a reader will actually see, Inactive - Failed to Renew, and the reactivation path out of it, are NMLS system policy rather than law. NMLS documents the status as taking effect January 1 and describes reactivation as the process used on or after January 1 to restore it, with the employing institution initiating and the originator then attesting. No NMLS page in the federal lane states an end date for that opportunity. See NMLS's own renewal and reactivation overview. The distinction matters because system policy can change without a rulemaking.

The employer's federal duty is separate and narrower. 12 CFR 1007.103(a)(2)(ii):

A covered financial institution must not permit an employee who is subject to the registration requirements of this part to act as a mortgage loan originator for the covered financial institution unless such employee is registered with the Registry pursuant to this part.

That reaches covered depositories only. The SAFE Act's own prohibition at § 5103(a) reaches the individual alone and imposes no duty on an employer.

State-licensed originators: a statute expires the licence

This lane is harsher, time-boxed, and written down. Texas is the cleanest worked example because all three stages sit in consecutive subsections.

Tex. Fin. Code § 157.015(a):

A residential mortgage loan originator license issued under this chapter is valid through December 31 of the year of issuance and may be renewed on or before its expiration date

§ 157.016(a), the duty to stop:

A person whose residential mortgage loan originator license has expired may not engage in activities that require a license until the license has been reinstated or a new license has been issued.

§ 157.016(b), the priced window:

A person whose residential mortgage loan originator license has not been renewed before January 1 but who is otherwise eligible to renew a license, and does so before March 1, may renew the license by paying the commissioner a reinstatement fee in an amount that is equal to 150 percent of the required renewal fee.

§ 157.016(c), the cliff:

A person whose residential mortgage loan originator license has not been renewed before March 1 may not renew the license. The person may obtain a new license by complying with the requirements and procedures for obtaining an original license.

Wisconsin states the same cliff in six words. Wis. Stat. § 224.35(7)(c):

After the reinstatement period, an expired license may not be reinstated.

One caveat worth stating rather than glossing. Whether a lapse leaves a licence merely failed-to-renew or fully terminated turns on whether the state issues annual or perpetual licences. Every state code read for this piece expires the licence annually, so the terminated path is the normal case, but no source consulted names a perpetual state either way. Treat the rule as conditional on your own state's expiry language.

The window's start is mostly configuration, not law

November 1 is real, but it is usually a property of the system. Six federal banking agencies said so on the record in 2010, describing the state side as

the current system for originators regulated by a State is configured for an annual renewal period from November 1 through December 31

at 75 Fed. Reg. 44656, 44661-62. For the federal lane, by contrast, the dates are regulatory: 12 CFR 1007.102 defines the annual renewal period as November 1 through December 31 outright.

A meaningful minority of states codify the start anyway. Wisconsin, Nevada, South Carolina and Connecticut carry November 1 in statute, and California (10 CCR § 2758.7(b)) and Virginia (10 VAC 5-161-40(B)) carry it in regulation. Wisconsin puts both halves in the definitions, at § 224.35(1g)(d) and (1g)(c):

"Renewal period" means the period beginning on November 1 and ending on December 31, or such other period prescribed by the division.

"Reinstatement period" means the period beginning on the first day of January and ending on the last day of February of the year following the expiration of a license, or such other period prescribed by the division.

Note the escape clause in both: or such other period prescribed by the division. Even where the dates are statutory, they are often defaults the regulator may move.

The deadlines that are earlier than December 31

This is where a roster-wide calendar goes wrong, because the NMLS window is uniform and the regulators underneath it are not.

Georgia: December 1. Rule 80-11-4-.12 governs renewal periods for mortgage brokers, lenders and loan originators:

Subsequent renewal applications and/or license fees must be received on or before December 1 of each year or the applicant will be assessed a late fee as set forth in these rules by license type.

The same rule keeps the licence expiring December 31 and the window open November 1 to December 31, so a Georgia renewal filed December 15 is inside the NMLS window and already late under Georgia's own rule. Georgia also declines to promise an outcome: where a proper application is not received by December 1, it states that issuance before January 1 cannot be guaranteed. A late Georgia renewal is therefore two risks, a fee and a gap in authority.

Illinois: 30 days before expiry, and the word is "received". 205 ILCS 635/2-6(a):

Properly completed renewal application forms and filing fees may be received by the Secretary 60 days prior to the license expiration date, but, to be deemed timely, the completed renewal application forms and filing fees must be received by the Secretary no later than 30 days prior to the license expiration date.

Two details matter. The test is receipt, not submission, so transit time is the licensee's problem. And 30 days is a timeliness standard rather than a bar on filing: § 2-6(b) is what bites, providing that failure to file timely, absent a written extension, "will result in the license becoming inactive," and § 2-6(c) that

No activity regulated by this Act shall be conducted by the licensee when a license becomes inactive.

Illinois prices the way back at double: reactivation requires the renewal fee plus a reactivation fee equal to the renewal fee.

Eight more states at December 1, plus two outliers. Delaware, Hawaii, Iowa, Idaho, Kansas, Minnesota, Vermont and Wyoming set the individual MLO renewal deadline at December 1. Washington sets December 15. West Virginia sets November 2. Those dates come from the per-state renewal chart NMLS publishes and republishes each season, so pull it for the year you are in rather than trusting last year's copy or this list. Confirmed 2026-10-08.

Reinstatement is not one window

The common description is January 1 through the last day of February for participating states. That is the right shape at the wrong precision for a compliance calendar, and it is a system default rather than a general rule. It comes from NMLS's own reinstatement-period documentation, not from federal law: Regulation H requires renewal only "no less often than annually" at 12 CFR 1008.103(f) and sets no calendar and no reinstatement provision at all.

Of the individual-licence rows in NMLS's current chart, 58 allow reinstatement and 14 do not. Of those that do, most end February 28, and seven end earlier, the earliest in mid-January. Ohio ends February 15 on that chart, which matches its statute.

The cleanest evidence that the February date is policy riding on state law is a note South Carolina's Department of Consumer Affairs puts inside NMLS's own chart, to the effect that NMLS states February 28 as the reinstatement deadline but South Carolina's is January 31 by statute. A regulator correcting the system default in the system's own document is the whole dynamic in one line.

State	Renewal deadline	Reinstatement	Late or reinstatement cost	Source
Georgia	December 1	not verified	late fee set by licence type	Rule 80-11-4-.12
Illinois	30 days before expiry	reactivation, no stated end	renewal fee plus a second fee equal to it	205 ILCS 635/2-6
Texas (SML)	December 31	before March 1	150% of the renewal fee	Tex. Fin. Code §§ 157.015, 157.016
Texas (OCCC)	December 31	Jan 1 to last day of February, rule only	conflicting: $50 by rule, $250 published	7 TAC § 2.104(d)
Florida	December 31	before March 1	$150 reinstatement fee	Fla. Stat. § 494.00313(3)
Washington	December 15	through last day of February	additional 50% of the annual assessment	WAC 208-660-350(15), (17)
Ohio	December 31	45 days, so February 14	$150 penalty	Ohio Rev. Code § 1322.21(C)(2)
California	December 31	Jan 1 through end of February	DRE states no late fee in that period	DRE MLO endorsement page
Wisconsin	December 31	Jan 1 to last day of February	$100 additional fee	Wis. Stat. § 224.35(1g)(c), (7)
New York	December 31	two independent 60-day clocks	none published	Banking Law
Pennsylvania	no statutory date	no statutory window	not applicable	see traps below
Oregon	rule-level, not verified	rule-level, not verified	not verified	ORS 86A.218 delegates both

This table is not complete, is not legal advice, and is not a substitute for your own states' rules. Every cell is either cited or explicitly marked unverified. Confirmed 2026-10-08.

Four rows need their own sentences.

Texas is two agencies, not one state. SML licenses under Finance Code Chapter 157 and carries the statutory "before March 1". The OCCC licenses under Chapter 180 with its calendar in rule only, worded "January 1 through the last day of February". Those phrasings come apart in a leap year. The OCCC's reinstatement fee is also unreconciled: $50 appears in 7 TAC § 2.104(d) and $250 on the agency's own website. Where a regulator contradicts itself, publish both with attribution or publish neither.

Washington expires the licence and then forbids the work during the cure period. WAC 208-660-350(17) allows renewal through the last day of February for "an additional fifty percent of your annual assessment," and says in the same breath:

During this two-month period, your license is expired and you must not conduct any business under the act that requires a license.

Subsection (18) adds a sting for anyone who waits it out: a new application is not complete until the originator proves they satisfied the prior period's continuing education. Letting a licence die does not clear the CE debt.

Florida renames the licence rather than killing it, for sixty days. Fla. Stat. § 494.00313(3) changes the status to the quoted term "failed to renew" pending review, charges a $150 reinstatement fee on top of registry fees, and then:

If the licensee fails to meet the requirements of this section and pay all required fees before March 1, such license is expired and such loan originator must apply for a new loan originator license under s. 494.00312.

Ohio's cure window closes February 14, not February 28. Ohio Rev. Code § 1322.21(C)(1) says a renewal fee received after December 31 means the licence "shall not be considered renewed, and the applicant shall cease activity as a mortgage loan originator." (C)(2) is the only way out, and it is short:

Division (C)(1) of this section shall not apply if the applicant, not later than forty-five days after the renewal deadline, submits the renewal application and any other required fees and a one-hundred-fifty-dollar penalty to the superintendent.

Forty-five days from December 31 is February 14. Any calendar that gives Ohio until the end of February is two weeks wrong.

The obligation to stop, and the employer's share of it

Every statute above bars the lapsed individual from working. California says it in the plainest language, on the DRE's own endorsement page:

Individuals and companies who fail to request the MLO license endorsement renewal between November 1st and December 31st will result in the MLO license endorsement expiring as of January 1st. The individual/corporation will be required to cease performing all activities that require a MLO license endorsement.

The DFPI puts the same thing in one sentence: if you do not submit a renewal request by December 31, your licence expires on January 1 and you are not authorized to originate loans. California's underlying statute, Cal. Bus. & Prof. Code § 10166.02(c), is equally terse: endorsements "shall be valid for a period of one year and shall expire on December 31 each year."

The part that makes this a company problem rather than an individual one is who else is liable. California makes paying the lapsed person the violation. Cal. Bus. & Prof. Code § 10137:

It is unlawful for any licensed real estate broker to retain, compensate, directly or indirectly, any person for performing any of the acts within the scope of this chapter who is not a licensed real estate broker, or a real estate salesperson licensed under the responsible broker retaining or compensating him or her, or to retain or compensate, directly or indirectly, any licensee for engaging in any activity for which a mortgage loan originator license endorsement is required, if that licensee does not hold a mortgage loan originator license endorsement

The sanction in that same section runs against the employer's own licence: the commissioner "may temporarily suspend or permanently revoke the license of the real estate licensee." The trigger is retain or compensate, so paying a commission on a file worked by a lapsed originator is itself the act.

Washington reaches supervisors through a knowledge standard rather than a payment. RCW 19.146.200(3) makes a designated broker, principal or owner responsible for a licensee's violations where that person

knows or by the exercise of reasonable care and inquiry should have known of the conduct, at a time when its consequences can be avoided or mitigated and fails to take reasonable remedial action

"Should have known" is the operative phrase for a licensing team: not knowing a roster member lapsed is not obviously a defence. Washington also makes an unsponsored licence a dead one, at WAC 208-660-350(9): an inactive licence holder "may not conduct any of the activities of a loan originator, or hold themselves out as a licensed loan originator."

No enforcement action is cited here, and none should be inferred. The point is the exposure written into the statutes, not a prediction about how often it is used.

Four citation traps

Each of these is a plausible-looking citation that does not say what it appears to. They are collected because a wrong citation in a compliance file is worse than no citation.

1. [1]

   12 CFR 1007.102 is the wrong lane

   It defines "annual renewal period", which makes it look like the governing authority for any MLO renewal. Part 1007 is Regulation G and governs federally registered originators only. For state-licensed originators the federal standard is 12 U.S.C. § 5105, titled "Standards for State license renewal", and the calendar is state law plus NMLS policy.

2. [2]

   7 Pa. Cons. Stat. § 6139(b) is not an annual grace period

   It is headed "Reinstatement", which is why it gets miscited. It is a disciplinary mechanism for licences previously suspended or revoked, not a route back from a missed annual renewal. Pennsylvania has no statutory renewal date and no statutory window.

3. [3]

   Oregon's December 31 belongs to a different licence

   ORS 86A.218 is titled "License renewal; expiration; reinstatement; rules" and contains no deadline, no window and no penalty: subsection (2)(b) delegates reinstatement procedure to rule, and its only hard requirement bites on lapses of five years or more. The December 31 and the one-year term elsewhere in chapter 86A sit in ORS 86A.109, which governs mortgage banker and broker licences. Do not cite either for an MLO.

4. [4]

   Texas: § 180.059, and 7 TAC Chapter 81

   § 180.059 carries no date, fee or window, so reading it suggests Texas has no statutory reinstatement provision. The operative section for SML licensees is § 157.016. Separately, 7 TAC Chapter 81 does not exist: SML's rules were reorganised into 7 TAC Part 4, Chapter 55 effective 2024-11-23 (49 TexReg 9203). A citation to Chapter 81 is a sign the source has not been checked since 2024.

Two more worth knowing. Nev. Admin. Code 645F contains the phrase a searcher wants, "before February 28", and governs mortgage servicers rather than originators. And Wis. Stat. § 224.35 is titled "Nationwide multistate licensing system and registry", not the MLO section: the MLO section is § 224.725, and § 224.725(5) routes renewal back out to § 224.35(7).

A sourcing note for anyone verifying Texas independently. statutes.capitol.texas.gov now serves an identical JavaScript shell on every path, including its /Docs/ HTML and PDF routes. The readable source behind it is the Legislature's own static file server, for example FI.157. It carries no "current through" banner, so do not quote a currency date from it.

Why this is a roster problem, not a calendar problem

One originator in one state is a date in a calendar. Scale changes both the arithmetic and the failure mode.

Filing early is also the only lever with evidence behind it. The operator of NMLS reported in December 2014 that historically 80 percent of applications submitted by December 15 were approved by December 31, against 46 percent when the request came after December 15, and that 94 percent of renewals filed during November were approved in time. Those figures come from a since-archived media release and that statistical series was discontinued; state regulators now publish a general "renew early" advisory each October instead. Treat the numbers as the best available evidence of a real effect rather than as a current measurement.

The work that makes a December filing possible is not December work. Continuing education has to be complete and reported, the record accurate, and sponsorships current before anyone can attest. That sequencing, and why a roster that starts on November 1 is already late, is the subject of its own note.

Frequently asked

Is December 31 the NMLS renewal deadline?

It is the end of the NMLS filing window. At least eleven states set an earlier effective deadline, including eight at December 1, Georgia at December 1 by rule, Washington at December 15 and West Virginia at November 2.

What happens if an MLO misses December 31?

It depends on the lane. A federally registered originator moves to Inactive - Failed to Renew, which reactivation clears with no stated deadline, under NMLS policy that no regulation describes. A state-licensed originator's licence expires by statute, they may not originate, and the window to fix it is finite: Texas and Florida end it on March 1, Ohio on February 14, South Carolina on January 31, and fourteen agencies never open it at all.

Can a lapsed originator keep working while the renewal is pending?

No, and Washington says so while the cure window is still open: during the two-month reinstatement period "your license is expired and you must not conduct any business under the act that requires a license." Texas § 157.016(a) and California's DRE say the same. Treat that as the default and verify your own state rather than assuming a grace period exists.

Is the company exposed if a lapsed originator keeps originating?

In some states, yes, and independently of the individual. California makes it unlawful to retain or compensate someone for activity requiring an endorsement they do not hold, with the employer's own licence at risk. Washington makes a supervisor responsible where they knew or should have known.

How long is the reinstatement period?

Commonly January 1 to the last day of February, but that is an NMLS system default rather than a universal rule, and state law overrides it in both directions. Ohio's statute gives 45 days. Texas SML says "before March 1" while the Texas OCCC says "the last day of February", which differ in a leap year.

Sources

• SAFE Act, 12 U.S.C. § 5103 (annual maintenance duty, individual only)
• Regulation G, 12 CFR Part 1007, especially 1007.102, 1007.103(a)(1), (a)(2)(ii) and (b) (duty to renew; no lapse consequence stated anywhere in the part)
• NMLS on renewal and reactivation in the federal lane and the state reinstatement period, both system policy rather than law
• Renewal deadlines, requirements and fees chart, republished each season
• Texas Finance Code §§ 157.015 and 157.016, via the Texas Legislature's static file server; Texas OCCC 7 TAC § 2.104(d)
• Georgia Rule 80-11-4-.12
• 205 ILCS 635/2-6
• Fla. Stat. § 494.00313
• WAC 208-660-350 and RCW 19.146.200
• Ohio Rev. Code § 1322.21
• Wis. Stat. § 224.35
• Or. Rev. Stat. ch. 86A, § 86A.218 and § 86A.109
• California DRE MLO endorsement page, DFPI MLO FAQs, and Bus. & Prof. Code §§ 10137 and 10166.02 in DRE's published law book
• 75 Fed. Reg. 44656, at 44661-62
• Conference of State Bank Supervisors media release, 2014-12-02, archived