Mastering Mortgage Brokerage Compliance: Your Essential 2025 Guide to Staying Ahead

Compliance is the backbone of every well-run mortgage brokerage. Missing a key filing or deadline can result in penalties, disruptions to your business, or even regulatory action. To keep your brokerage running smoothly in 2025, here’s a comprehensive compliance calendar highlighting the essential dates and actions mortgage broker owners need to manage in NMLS. 

Key Compliance Activities for Mortgage Broker Owners 

Key Compliance Activities for Mortgage Broker Owners

1. Mortgage Call Reports (MCR) Filing Deadlines

Mortgage Call Reports (MCRs) are a critical component of NMLS compliance, providing regulators with insights into your business activity. These must be filed quarterly. 

  • Q4 MCR due February 14, 2025

Covers activity from October 1 to December 31 of 2024.

  • Q1 MCR Due May 15, 2025 

Covers activity from January 1 to March 31 of 2025. 

  • Q2 MCR Due August 14, 2025 

Covers activity from April 1 to June 30 of 2025. 

  • Q3 MCR Due November 14, 2025 

Covers activity from July 1 to September 30 of 2025. 

  • Q4 MCR Due February 14, 2026 

Covers activity from October 1 to December 31 of 2025. 

Tip: Start compiling data monthly so it’s easier to complete your MCR in time. Double-check figures for accuracy before submission.  Want help? SCP has templates or can do them for you!

2. Annual NMLS Renewal Period 

The NMLS Annual Renewal season runs every fall. During this period, you must renew your company, branch, and individual mortgage loan originator (MLO) licenses. 

  • Renewal Opens: November 1, 2025 
  • Deadline to Submit Renewal: December 31, 2025 

Ensure everyone on your team has completed their renewal requirements, such as Continuing Education (CE), before applying. If you miss the deadline, you may face late renewal penalties or licensing interruptions. Many states have early renewal deadlines, it is important to review these requirements on a state by state basis to ensure a timely submission. 

3. Continuing Education (CE) Deadlines 

All licensed mortgage loan originators must complete 8 hours of Continuing Education (CE) annually. This typically includes a mix of federal law updates, ethics, and non-traditional mortgage lending topics. 

  • Deadline to Complete CE: December 26, 2025 

Many states have early continuing education deadlines, it is important to review these requirements on a state by state basis to ensure a timely completion. 

Pro Tip: Don’t wait until December. Many CE providers get overwhelmed in the final weeks of the year, causing delays. Complete your CE by October or earlier to avoid stress.  Check out SCP’s partner, Oncourse Learning for CE support!

4. Financial Condition (FC) Filings 

For companies using the NMLS, an annual financial condition report must be submitted to maintain compliance. 

  • For mortgage lenders and servicers, the FC is due quarterly at the same time as the RMLA.
  • For mortgage brokers, the FC is due annually, within 90 days of the calendar year end.

For most companies, the 2025 FC filing will be due March 31, 2025

Double-check if your state has any specific requirements or formats for this filing, as they can vary. 

5. Annual Financial Statement 

For companies using the NMLS, an annual financial statement must be submitted to maintain compliance. 

  • The annual financial statement is due within 90 days of the calendar year end.
  • Financial statement requirements are state specific and may require mortgage lenders and brokers to demonstrate a minimum net worth. 
  • Companies may be required to provide compiled, reviewed, or audited financial statements prepared by a Certified Public Accountant (CPA). 

For most companies, the 2025 Annual Financial Statement will be due March 31, 2025

6. NMLS Record Maintenance

Keeping your NMLS records updated is more than an annual task; it’s an ongoing obligation. 

Update Required Information 

If any of the following change, update the NMLS immediately:

  • Ownership structure 
  • Business address 
  • Company officers 
  • Legal company name 
  • Addition or removal of a DBA

Failure to update your NMLS record accurately or timely can lead to compliance violations. Many changes require companies to file an Advance Change Notice (ACN) which requires notification to the state regulators before the effective date of the change. 

Schedule quarterly reminders to review your records for accuracy.  Try performing an annual mock audit to ensure your documents are all in order!

7. Licensing Exams and Audits 

Many jurisdictions conduct periodic audits or exams of licensed mortgage brokerages. While these reviews do not follow a strict schedule, proactive preparation ensures compliance when the time comes. 

What to Expect: 

Examiners will review your policies, loan files, advertisements, and communications to ensure they align with state and federal regulations. 

Preparation Tips: 

  • Maintain organized and accessible records. 
  • Regularly review ads for compliance with marketing laws. 
  • Have a compliance officer conduct internal audits quarterly. 

8. State-Specific Filings and Deadlines 

Compliance calendars can vary by state. Beyond NMLS filings, you may have state-specific deadlines for license renewals, corporate filings, or other regulatory submissions

Examples: 

  • Annual state business filings (contact your Secretary of State office for due dates). 
  • State-specific financial reporting. 
  • Local business license renewals 

Check with your local and state regulator for specific compliance deadlines for 2025. 

How to Stay on Top of Deadlines 

How to Stay on Top of Deadlines

1. Leverage an NMLS Dashboard 

The NMLS dashboard provides reminders for renewal and filing deadlines. Set notifications to ensure nothing slips through the cracks.  Here at SCP, we ensure our clients get the notifications for important deadlines or offer programs to manage the process for them!

2. Use a Compliance Calendar Tool 

Integrate deadlines into a task management tool like Google Calendar, Trello, or Monday.com. Assign team members to oversee specific compliance tasks.  Or… ask SCP to manage it for you, so you can focus on the borrower and less on the compliance.

3. Train Your Team 

Compliance is a team effort. Host training sessions with your MLOs and operations staff to ensure everyone understands their responsibilities for key deadlines. 

4. Perform Quarterly Reviews 

Schedule quarterly compliance reviews to make sure all filings, licenses, and policies are up to date. Proactive reviews save headaches closer to major deadlines. 

5. Partner with SCP

If your brokerage operates in multiple states or handles high loan volumes, consider hiring a compliance consultant to help manage state-specific regulations and audit preparation. Strategic Compliance Partners (SCP) can assist with compliance, NMLS maintenance, licensing, and more. Visit www.strategiccompliancepartners.com for details. 

Want Help Maintaining Your Brokerage?

Compliance might not be flashy, but it’s essential for the success and reputation of your mortgage brokerage. By following this 2025 Compliance Calendar and staying ahead of deadlines, you’ll save time, avoid penalties, and create a stronger, more reliable business. If you’d like more compliance tips or need help streamlining your processes, reach out—our team is here to help mortgage brokers thrive. 

Stay compliant and successful in 2025! For additional support, contact us today at 301.578.6015 for a free compliance evaluation of YOUR brokerage.

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About Ari Karen

Ari Karen is an experienced litigator who has focused his practice in representing financial institutions in both government investigations and litigation before state and federal trial and appellate courts nationwide. Mr. Karen’s practice is diverse, representing clients on matters concerning banking regulations, Dodd Frank financial reform laws, contractual disputes, employment and labor statutes, wage-hour class actions, employment discrimination and fair lending matters, whistleblower complaints and non-competition claims, among others.

Mr. Karen speaks regularly on topics affecting all types of lenders including fair lending and disparate impact, LO compensation, marketing service agreements, compliance with social media, non QM lending, vendor management, and much more. Mr. Karen is a principal in the Financial Institutions Regulatory and Labor and Employment practice groups of the Offit Kurman law firm.