Effective April 2026, the NMLS has launched revised MU2 individual disclosure questions, introducing critical definitional changes and broader regulatory scopes that all California Finance Law licensees must retroactively complete by August 31, 2026. Failure to update these mandatory disclosures could stall company license filings and jeopardize your upcoming annual renewal.
On April 18, 2026, the Nationwide Multistate Licensing System (NMLS) implemented revised individual disclosure questions on the MU2 portions of the NMLS. All California Finance Law (CFL) licensees (and applicants) must answer these new questions. According to the DFPI, the questions were revised to clear up potential confusion in the prior questions, since those questions had not been “holistically” reviewed since their inception of NMLS back in 2008. This requirement is retroactive* and compliance by all licensees (and applicants) is mandatory.
There are a number of substantive changes, presumably reflecting the “holistic” review. A consumer protection authority and governmental entity have been added to the list of regulatory bodies addressed in some of the questions, broadening the scope of their disclosures. On the other hand, the misdemeanor inquiry has been limited to 10 years. And, a new category of “not applicable” will be available for certain questions which have caused some consternation in the past.
Here is a broad synopsis of the technical aspects that you should know:
- The DFPI is recommending that the new questions be completed by August 31, 2026. It is unclear whether there will be a penalty for lack of compliance, but I suspect you will not be able to renew your license annually if you do not update your disclosures, which one might construe as a penalty.
- You will not be able to submit a revised MU1 (for the company’s main office) or a revised or new MU3 (for the company’s branch office) unless the new disclosures have been completed.
- All control persons, branch managers and qualifying individuals must complete the revised questions. Since the MU2 is attached to the MU1 and MU3, attestation and resubmission of the MU1’s and MU3’s will be necessary as well.
- *It is important to note that the term “retroactive” means, in this context, much more than simply requiring existing licensees to answer the same questions again using the original answers. There are new definitions and explanations that may change the context of a question. If so, an answer that was accurate prior to the revisions may need to be changed based on the definitional changes.
These changes relate to the individual disclosures in the MU2 (and, for you mortgage loan originators, the MU4). Company disclosures found in the MU1, will also be revised, but probably not until next year.
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