No, MLOs that are registered with the NMLS and employed by financial institutions are not required to register or obtain state-issued licenses in Illinois. Consequently, the NMLS-registered MLOs at your bank are not required to complete the continuing education requirements for Illinois-licensed MLOs.

Although the Illinois Residential Mortgage License Act of 1987 generally requires licensed MLOs to complete eight hours of continuing education each year, among other requirements, MLOs that are registered with the NMLS and employed by financial institutions are exempt from these requirements.

For resources related to our guidance, please see:

• Illinois Residential Mortgage License Act of 1987, 205 ILCS 635/1-3(a) (“No provision of this Act shall apply to an exempt person or entity as defined in items (1) and (1.5) of subsection (d) of Section 1-4 of this Act.”)

• Illinois Residential Mortgage License Act of 1987, 205 ILCS 635/1-4(d)(1) (“‘Exempt person or entity’ shall mean the following: (1) . . . any national bank, federally chartered savings and loan association, federal savings bank, federal credit union; . . . any bank, savings and loan association, savings bank, or credit union organized under the laws of this or any other state; . . .”)

• Illinois Residential Mortgage License Act of 1987, 205 ILCS 635/1-4(d)(1.5) (“‘Exempt person or entity’ shall mean the following: (1.5) Any employee of a person or entity mentioned in item (1) of this subsection, when acting for such person or entity, or any registered mortgage loan originator when acting for an entity described in subsection (tt) of this Section.”)

• Illinois Residential Mortgage License Act of 1987, 205 ILCS 635/7-7(a) (“In order to meet the annual continuing education requirements referred to in Section 7-6, a licensed mortgage loan originator shall complete at least 8 hours of education approved in accordance with subsection (b) of this Section, which shall include . . .”)