SAFE MLO Test (NMLS Mortgage Loan Originator Test) guideThe SAFE MLO test in 2027
MLO License Renewal and CE for 2027: The 8 Hours, the December 5 SMART Deadline and Late CE
To keep an MLO license for 2027, you renew in NMLS between November 1 and December 31, 2026, after your 2026 CE is posted; NMLS suggests finishing CE by December 5. Some states close earlier. CE taken in 2027 then counts toward renewing for 2028. Here are both calendars, the state deadlines and what happens if you miss them.
Short answer
To keep a state MLO license for 2027, you renew in NMLS between November 1 and December 31, 2026. NMLS won't accept the renewal until your 2026 CE is posted: at least 8 hours (3 federal law, 2 ethics, 2 nontraditional lending, 1 elective) plus any state hours. NMLS encourages finishing by its SMART CE deadline of December 5, and several states set December 1 or 15 deadlines. CE you take in 2027 counts only for renewing for 2028, between November 1 and December 31, 2027, and it can't repeat a course you took in 2026.
"MLO renewal for 2027" can mean two different deadlines: the renewal you file at the end of 2026 to stay licensed in 2027, and the CE you'll take during 2027 to renew for 2028. They use the same rules but different calendars, so this guide gives both.
Two 2027 MLO renewal calendars
| Renewing to stay licensed in 2027 | Keeping the license into 2028 | |
|---|---|---|
| Renewal window in NMLS | November 1 to December 31, 2026 | November 1 to December 31, 2027 |
| CE that counts | Courses completed in 2026 | Courses completed in 2027 |
| NMLS's SMART CE deadline | December 5, 2026 | December 5, 2027 |
| Reinstatement, where the state allows it | January 1 to the end of February 2027 | January 1 to the end of February 2028 |
NMLS's licensing guide sets the November 1 to December 31 window "each year," and its reinstatement page gives the January–February period, which some states shorten (see below). California's Department of Real Estate has already posted its dates for this cycle: its MLO endorsement renewal period runs from November 1, 2026 through December 31, 2026.
The 8 hours of MLO continuing education
The SAFE Act and Regulation H (12 CFR 1008.107) require at least 8 hours a year and set three of the topics; NMLS's CE FAQ describes the remaining hour as an elective:
- 3 hours of federal law and regulations
- 2 hours of ethics, including fraud, consumer protection and fair lending
- 2 hours on lending standards for the nontraditional mortgage product marketplace
- 1 hour of undefined instruction on mortgage origination (an elective)
Four rules decide whether a course counts:
- Credit only in the year taken. Hours from 2026 can't be applied to 2027, and extra hours don't carry forward
- No repeats two years in a row. The SAFE Act bars taking the same approved course in the same or successive years, and NMLS reads "successive years" as two years in a row. Courses that share licensed content count as the same course, so check last year's course titles in your NMLS education record before you register
- Instructors earn double. An approved CE instructor gets 2 hours of credit for every hour taught (12 U.S.C. 5105(b)(4))
- NMLS checks both federal and state CE. Its FAQ says NMLS validates both before it lets you apply to renew
NMLS has already published its CE Required Topic List for annual CE year 2027, which covers CE delivered between January 1 and December 31, 2027, next to the 2026 list. If the federal rule changes behind this year's courses are new to you, the guide to 2027 federal rule changes lists them with effective dates, and explanations that restate a rule in simpler terms with AI Rescue are planned for launch.
State CE hours on top of the 8
NMLS's state-specific table (August 2026 version) lists agencies that require state hours. Where the total stays at 8, the state hour sits inside the 8; where it's higher, you take more:
| Agency | State CE hours | Total CE hours |
|---|---|---|
| New Jersey | 2 | 12 |
| New York | 3 | 11 |
| Oregon | 2 | 10 |
| Washington | 1 | 9 |
| Utah (DRE) | 1 | 9 |
| West Virginia | 2 | 9 |
| California (DFPI), Florida, Georgia, Massachusetts, Pennsylvania and others | 1 | 8 |
Licensed in several states? Each state's hours apply, and NMLS's FAQ gives an example: an MLO licensed in Oregon who adds a Washington license in 2021 still had to complete 2021 CE, including the Washington hour, to renew both.
MLO renewal deadlines earlier than December 31
NMLS's window closes on December 31, but your state may want the request sooner. In the CSBS Renewal Deadlines, Requirements, and Fees Chart that NMLS links to, downloaded on October 28, 2026, these MLO licenses show an earlier submission deadline:
| Deadline | Agencies |
|---|---|
| December 1 | Delaware, Hawaii, Idaho, Iowa, Kansas, Minnesota, Vermont, Wyoming |
| December 15 | Washington (requests can be filed until December 31, but the chart says they must be in by December 15 to be reviewed before year-end) |
Delaware's own FAQ confirms its date: renewals open through NMLS on November 1 and must be submitted no later than December 1.
Two other columns in the same chart matter for planning:
- Pending on January 1. Many agencies let you keep working if you filed in time and the state hasn't decided yet, but the chart lists others where the renewal must be approved before you can originate in the new year, among them New York, Virginia, Washington, Minnesota, Missouri and Arkansas
- New background or credit checks. Some agencies require a new criminal background check, a new credit report, or both, at renewal. The chart marks both for New York, Washington, Florida and Massachusetts, among others
The chart is updated by each agency. Filter it to "Individual" and your states before you plan around a date.
What NMLS checks before your MLO renewal goes through
NMLS's licensing guide lists the steps: review and update your record, complete CE as your states require, confirm your background check and credit report are current, attest for each license, and pay the renewal fees. A license with open license items or deficiencies may need them resolved first.
For the renewal at the end of 2026, two record updates were flagged in advance:
- Revised disclosure questions. NMLS planned to deploy revised individual disclosure questions in spring 2026, and California's Department of Real Estate reports they've been implemented. NMLS's FAQ says they're retroactive, so you answer them as if for the first time, and it strongly encouraged completing them by August 31, 2026. The Department of Real Estate told its licensees to complete these updates no later than October 31, 2026, to prepare for the 2027 renewal cycle
- Work-remote status. NMLS's guidebook says companies were directed to complete their MLOs' work-remote details by August 31, 2026, to prepare for 2027 renewals
NMLS also places a CE license item on licenses that aren't yet CE-compliant on or around July 15 each year, and sends monthly reminders, so an item on your record in late summer is a prompt rather than a penalty.
If you miss the MLO renewal deadline
- Reinstatement. If you don't file by December 31, NMLS says you may be able to reinstate between January 1 and the end of February, if your state allows it. The CSBS chart lists agencies that don't, including Connecticut, Georgia, Maryland, New Hampshire, Oklahoma, Tennessee and Utah (DFI), and some that close it sooner: January 15 for Arkansas, January 30 for Kentucky, January 31 for Arizona, North Dakota and South Carolina, and February 15 for Ohio
- Extra cost. Reinstatement can carry fees. Arizona's entry in the chart, for example, adds $25 for each calendar day after December 31, and Washington's rule adds 50% of the annual assessment
- No business while lapsed. Washington's rule says that during the reinstatement period the license is expired and you must not conduct business that requires it. Colorado's Division of Real Estate says the same about failing to renew by December 31
- Late CE. If a state regulator tells you to make up CE from a past year, NMLS runs a Late CE Course Catalog for exactly that. Washington, for example, requires proof of the prior period's CE before it will consider a new application complete
MLO renewal rules for your first year
Two exceptions mean a new licensee may owe no CE in the first year:
- Pre-licensing in the same year. NMLS's Uniform CE Policy waives CE for the year in which you reached federal pre-licensing compliance, if your license was approved that same year
- Licensed in November or December. NMLS's CE FAQ says an MLO licensed between November 1 and December 31 doesn't need CE for that year
The 2027 MLO license timeline shows how these play out if you're getting licensed during 2027.
A note for MLOs coming back after a lapse
Renewal keeps a license alive; it can't restart one that's gone. If you've been out of the industry, two clocks may have run: a passing SAFE MLO result expires after 5 years without a license, and pre-licensing education after 3 years in agencies that enacted NMLS's policy. The test and education expiration guide explains both. If you do have to retest, a 120-question timed mock exam for a retest after a long break is planned for launch.
Next step for your 2027 MLO renewal
- Open your NMLS education record and check your 2026 CE status and last year's course titles
- Finish CE by December 5, earlier if your state's deadline is December 1
- Filter the CSBS renewal chart to your states and note each deadline and fee
- Update your disclosure answers and resolve any license items
- Submit the renewal and attest for each license before your earliest state deadline
If a colleague or new hire is still working toward the test, the free SAFE MLO practice questions are a quick starting point, and they can compare the planned prep periods for new SAFE MLO candidates; checkout isn't open yet.
Trust the source
Official sources
Exam policies can change. Use these primary sources for the most current details.
- Renewing Individual Licenses or Registrations (NMLS Licensing for Individuals)NMLS↗
- Reinstating Individual Licenses or Registrations (NMLS Licensing for Individuals)NMLS↗
- Gathering Renewal Requirements (NMLS Licensing for Individuals)NMLS↗
- Renewal Deadlines, Requirements, and Fees Chart (Excel download)Conference of State Bank Supervisors (NMLS)↗
- Education FAQ: Continuing Education (CE)NMLS↗
- State-Specific Education Requirements (PE and CE)NMLS↗
- NMLS Policy Guidebook: Uniform CE PolicyNMLS↗
- NMLS Policy Guidebook: SAFE Act's Successive Year RuleNMLS↗
- NMLS Approved Education: Policies and Notices (CE Required Topic Lists for 2026 and 2027)NMLS↗
- Complete NMLS Approved Courses (Late CE Course Catalog)NMLS↗
- NMLS Policy Guidebook for Licensees (updated July 15, 2026)NMLS↗
- Disclosure Question FAQs (revised individual disclosure questions)NMLS↗
- 12 CFR 1008.107: Minimum annual license renewal requirements (Regulation H)eCFR (Office of the Federal Register)↗
- 12 U.S.C. 5105: Standards for State license renewalU.S. Government Publishing Office (govinfo)↗
- Mortgage Loan Origination (MLO) - NMLS/SAFE ActCalifornia Department of Real Estate↗
- Mortgage Loan Originator Licensing HelpDelaware Office of the State Bank Commissioner↗
- WAC 208-620-710: Mortgage loan originator, licensingWashington State Legislature↗