The Nationwide Multistate Licensing System (NMLS) has introduced updated disclosure questions for individuals completing MU4 and MU2 forms, marking the first substantive revision since the system’s inception.

These changes are intended to improve clarity and consistency in how disclosure information is reported. However, they also require a comprehensive review of existing filings to ensure alignment with the revised framework.

What’s Changing

NMLS has updated its individual disclosure questions to reduce ambiguity and improve interpretability for both filers and regulators.

While the structure of the forms remains familiar, the revised questions introduce important nuances that may affect how prior disclosures should be interpreted and reported going forward.

Who Is Affected

The updates apply to individuals required to submit MU4 or MU2 filings, including:

• Loan originators
• Control persons
• Branch managers
• Qualifying individuals

Organizations should expect a broad impact across licensed personnel and ensure all applicable individuals are prepared to review and update their filings.

Key Requirement: Re-Answer as New

A critical aspect of this update is that disclosure questions must be completed as though they are being answered for the first time.

Although previous responses will remain visible within the system, individuals are expected to:

• Review all prior disclosures in full
• Update responses to align with revised question language
• Remove outdated or no-longer-relevant information

This is not a carryforward exercise. Each response should be evaluated against the updated requirements to ensure accuracy and completeness.

Key Dates

• April 18, 2026: Updated disclosure questions become available
• August 31, 2026: Deadline to complete all required updates

This implementation window is designed to allow regulators sufficient time to review submissions ahead of the annual license renewal cycle.

How to Prepare

To avoid last-minute remediation and potential compliance risk, organizations should begin preparation now:

• Identify all individuals required to complete MU4 or MU2 filings
• Communicate upcoming changes and expectations clearly
• Allocate time for review and updates across impacted roles
• Establish internal review or quality control processes

Early action will help ensure filings are accurate, complete, and aligned with regulatory expectations.

Additional Resources

NMLS has published a Disclosure Question Resource Center, which includes:

• Frequently asked questions
• A summary of changes
• Detailed guidance for each revised question

Organizations are encouraged to leverage these resources as part of their review and update process.

Supporting Compliance Execution

As disclosure requirements evolve, maintaining consistency, accuracy, and audit readiness becomes increasingly complex. With the August 31 deadline approaching, organizations should treat this update as a priority to ensure disclosures are accurate, defensible, and aligned with evolving regulatory expectations.