On September 26, 2025, financial regulators in Hawaii, Idaho, Oregon, and Texas entered into a multistate Settlement Agreement and Consent Order with a mortgage company to resolve allegations of unlicensed activity, inadequate supervision, and examination noncompliance under each state’s mortgage licensing laws. The agreement followed a coordinated multistate examination conducted in October 2023.
The participating regulators alleged that the company violated multiple provisions of their respective state’s mortgage lending and loan originator licensing acts between 2021 and 2023. The states cited unlicensed origination and processing activity, failure to cooperate during examinations, and insufficient oversight of remote work arrangements as constituting improper or dishonest conduct. The company neither admitted nor denied the allegations and entered into the settlement to resolve the matter without further proceedings.
Under the consent order, the company agreed to pay $669,000 in administrative penalties, of which $501,750 is due upon execution and $167,250 will remain in abeyance for one year, accruing interest at one percent per month. The abeyance portion becomes immediately payable if the company fails to comply with the agreement or resumes unlicensed activity.
Putting It Into Practice: The settlement marks another enforcement action targeting unlicensed lending activities (previously discussed here). Mortgage lenders and brokers must ensure that all originators and processors are properly licensed or registered in each state where they operate. Failing to do so invites enforcement, administrative penalties, and reputational risk.