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Question: We’ve heard talk for years about potential revisions to the NMLS Disclosure questions. Is it really happening or is this a belated April Fool’s joke?

Answer:

This is not a joke. The revised Disclosure questions for Individuals (MU-2 and MU-4) will be implemented in NMLS on April 18, 2026. This means that on or after April 18, 2026, all MU-2 individuals (Control Persons, Branch Managers and Qualifying Individuals) and MU-4 individuals (Mortgage Loan Originators) will be required to review and answer all of the revised Disclosure questions. Since the MU-2 is attached to MU-1 (Company) and MU-3 (Branch) filings, companies will have to initiate the update on behalf of all of their MU-2 filers and resubmit their MU-1 and MU-3s. A licensee will not be able to file a MU-1 or MU-3 on or after April 18, 2026 unless the MU-2 Individuals complete the revised Disclosure questions and attest to them.

As such, state regulators are strongly encouraging MU-2 and MU-4 filers to complete the questions as soon as possible and by August 31, 2026, so any changes can be reviewed by agencies well in advance of renewal season.

On April 18, 2026 a License Item will be placed on all MU-2 and MU-4 Individuals’ records in NMLS. Email notifications will not be sent when such License Items are placed.

Individuals will be able to see and use existing Disclosure explanations in their MU-2/MU-4 for the revised questions. Existing explanations can be amended or deleted, as needed. If amended or deleted, a reason must be provided for the amendment or deletion. State regulators recommend that if an Individual changes an existing explanation or if an answer goes from no to yes, the Individual state in the beginning of the document/explanation why the change was made.

Note, Company (MU-1) Disclosure questions will be revised at a later date (likely in 2027). It is important to understand that changes made to the Glossary now (i.e. amended and/or new terms terms) may affect Company Disclosure questions now. As such, licensees should review …

The Federal Individual Disclosure questions remain unchanged. This only affect state regulated entities.

A detailed summary of the revised Individual Disclosure Questions may be found here.

See the NMLS Resource Center’s Disclosure Questions Update page for additional information and resources.