Two Sponsors, One License: Priya's Weekend Files

Priya - the license is not portable. An MLO license is active only through the sponsoring licensee recorded in NMLS. Priya's sponsorship is Golden Gate, so every Summit application she took was unlicensed origination for Summit, even though her license is active. Holding a license and being sponsored are two separate facts; she satisfied only the first.

Summit (DRE jurisdiction). A DRE broker may only associate with and compensate MLOs whose licenses are active and sponsored by that broker. Paying 75 bps to someone it does not sponsor is paying compensation to an unlicensed person for brokerage activity, exposing Summit to discipline for unlicensed employment and dishonest dealing.

Golden Gate (DFPI/CRMLA jurisdiction). A CRMLA licensee is accountable for supervising the origination activity of its sponsored MLOs. Priya originated outside the sponsorship and paid a third party per loan while licensed through Golden Gate, so the audit obligation and failure-to-supervise exposure land on Golden Gate.

Aria (both). Pre-screening is arguably clerical; quoting rates and pricing while collecting documentation is not. Once she discusses terms, she is taking applications and must be NMLS-licensed. The $150-per-funding payment is per-transaction compensation to an unlicensed person - the classic prohibited referral arrangement.

Key line to draw: a salaried, clerical employee who collects contact information and forwards it is permissible; an unlicensed person who quotes rates negotiates and is not.

1. Suspend origination authority immediately - pull Priya from the pipeline before more files are contaminated. Every file she touched for Summit must be reviewed for disclosure and licensing-date defects, because lenders and investors have repurchase rights if origination occurred through an unsponsored MLO.
2. Stop the Aria payments and account for them. Per-loan payments to an unlicensed screener are prohibited compensation; Golden Gate must determine whether any of its own files were sourced through Aria and disclose the arrangement.
3. Fix the misrepresentation. A rate may be described as locked only against a lender's written lock confirmation with a stated expiration. Telling the borrower "locked" with no lock in place is a misrepresentation of a loan term and independently actionable regardless of who owned the file at that moment - Golden Gate cannot treat it as a Summit-only problem if the statement was made while she was held out as its MLO.
4. Report and document. Terminate or restrict the sponsorship in NMLS, retain the audit file, and make any required regulatory disclosure. Self-reporting plus documented remediation is the difference between a supervision finding and an concealment finding.
5. Remediate the borrower whose rate expectation was created and then broken, before the complaint arrives.

Sequence:

1. Priya terminates the Golden Gate sponsorship in NMLS (and Golden Gate must confirm the termination, not simply stop paying her).
2. Summit requests the sponsorship; the license shows Summit as sponsor and the address of the Summit branch she will work from.
3. Summit's designated broker confirms the location is covered by the brokerage's license and that supervision is in place.
4. Only once the license is active-with-Summit may she take applications or be paid by Summit.

While pending, she may not: take applications, quote rates as an MLO, prequalify, or receive compensation for files - from either company. Compensation for origination performed outside an active sponsorship is not curable after the fact; the loans do not become compliant because the transfer later completed.

Also verify: continuing education is current, the unique identifier used in her advertising changes to match her NMLS record, and the Summit files already originated during the unsponsored period are reviewed for lender notice obligations.