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The Surge In Dual “MLO and RE Agent” Licensing
The Surge In Dual “MLO and RE Agent” Licensing
The post presents key possibilities for agents to create additional income while growing a future client base and continuing to service their current client base by becoming dual-licensed MLOs.
California is the only state requiring MLOs to be licensed as real estate agents. Therefore, agents already have a ‘jump’ on the process.”
According to the director of Duane Gomer Seminars, Christine Olson:
“The earliest time it would take to get a MLO license would be 2 to 3 weeks; on average, most people take 4 weeks”. “A prospective MLO (with a DRE sales license) would need to complete a 20-hour ‘pre-licensing course’ whether by webinar or online reading program.”
“Webinars are usually 3-4 days, or if they want to do the online reading program, they can choose a 7—or 14-day package.”
“Once the agent has pre-licensing done, they sign up for the National Exam, pass the test, finish your background check, pay your $330.00 licensing fee, and you are all set”.
FYI: I have no financial business relationship with DG seminars other than attending their classes for 20 years. Enjoy the post, and email me if you have questions.
The NAR settlement has forced real estate agents to rethink their relationships with mortgage professionals.
Dual licensing for agents offers a path to greater control and higher earnings but also comes with compliance risks and regulatory uncertainty.
Navigating LO Comp, RESPA, and other legal hurdles will require careful planning and strict compliance.
For those who can adapt, though, dual licensing is more than a trend — it could be a decisive advantage in a shifting market.
As lenders and agents navigate this uncertain terrain, a key question looms: Is dual licensing the future of real estate or a legal and financial gamble?
California’s DRE is the only state agency requiring MLOs to be licensed as real estate agents. Buyer agents’ interest in dual licensing is reflected in a 2024 real estate agent survey by Hanover Research.
Hybrids Agents
Real estate and mortgage lending have always been closely connected, but some professionals are now blurring the line entirely.
1) Thirty-two percent of agents said they are pursuing or planning to obtain an MLO license.
2) Another 42% are considering it but have yet to take action.
3) The primary motivation is higher earning potential, as cited by 55% of those planning to become dual-licensed.
For lenders and brokers, the dual-licensing boom presents both a competitive opportunity and a compliance risk.
The Regulatory Minefield
While dual licensing has the potential to streamline transactions and boost revenue, conflicting federal regulations create significant hurdles.
Garris Horn, Attorney James Brody, warns that a lack of regulatory clarity could lead to serious legal and financial consequences for lenders adopting the model too quickly.
Even though FHA has allowed an individual to act as an agent and loan originator on FHA-insured transactions, the U.S. Department of Agriculture (USDA) explicitly prohibits it. “
FHA’s 2022 Mortgagee Letter allows double commissions with restrictions — namely, individuals with direct influence over mortgage approval (such as underwriters, appraisers, and inspectors) cannot hold dual roles.
Still, some lenders remain wary. Due to compliance concerns, many mortgage companies refuse to allow real estate agents to act as MLOs on the same transaction.
Brody sees this regulatory ambiguity as an ongoing concern. “The CFPB has not commented on whether [dual licensing] would be considered two separate transactions or just one,” he said.
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