Processors & Underwriters FAQs



These questions and answers constitute informal guidelines only and do not constitute legal advice or rules by DFI.  Any interpretations of Chapter 454F are specific to the facts and circumstances in each particular situation.  Questions and answers will be updated and supplemented as DFI develops additional guidance.  Additional answers can be found using the NMLS Resource Center.

If additional guidance is required on a unique situation in your company or for yourself, you may send your inquiryvia letter or email to:

Division of Financial Institutions
Department of Commerce and Consumer Affairs
P.O. Box 2054
Honolulu, HI 96805


[email protected]

If I am a loan processor or underwriter, working as an independent contractor, do I need to obtain an MLO license?

Yes.  Under both the federal SAFE Act and Chapter 454F, you are required to obtain an MLO license, and under Chapter 454F, if you are not an exclusive agent providing your services to one mortgage loan originator company only, you must also obtain an MLOC license.

See also the General FAQs.

If I am a loan processor or underwriter, and I am an employee, do I need to obtain an MLO license? 

No, provided that you are an “individual who performs clerical or support duties” as an employee at the direction of and subject to the supervision and instruction of an MLO, or a person who is exempt from licensing as an MLO under Chapter 454F.