Licensed in One State, Leads in Three

No - she cannot originate those loans.

• Under the SAFE Act and state law, an individual MLO must be licensed in the state where the dwelling securing the loan is located. The fact that Summit holds a State B license is irrelevant to Priya's own authority; a licensed company cannot lend through an unlicensed individual.
• Taking an application is originating. There is no 'just gathering information' exception once the conversation reaches the point of a residential mortgage loan application.
• The two State B applications she has already taken are unlicensed activity in State B. That is a reportable event for her State A license as well, since state regulators share NMLS records.

What she may do:

1. Hand the leads and the two existing applications to a Summit MLO who is licensed in State B, and step out of the transaction entirely - no origination, no negotiation, no compensation tied to those loans.
2. Or refer to a properly licensed third party, subject to the referral-fee rules of the relevant states.
3. Or wait until she is licensed in State B and sponsored there before contacting any of them.

She should report the premature applications to her compliance department now rather than hope they go unnoticed.

Temporary authority requirements (SAFE Act, as amended):

• She holds an active MLO license in her current state (State A).
• She has passed the SAFE national test with the uniform state component, and has no license revocation, suspension, or certain disciplinary/enforcement actions in the preceding year.
• She becomes an employee of a company that is licensed in State B - here, Summit qualifies.
• She has submitted a State B license application and meets the state's pre-licensing education and testing requirements.

Duration: temporary authority runs up to 120 days from the date she becomes employed by the State B-licensed company, and it ends when the State B license is granted or denied.

What it does not cover: it is authority in State B only. It does not travel. And it never converts into authority to originate in a state where she is not licensed.

State C: the vacation home is secured by property in State C, and neither Priya nor Summit is licensed there. Priya cannot originate that loan, even though the client and the application are in State A. The transaction must be handled by a lender and MLO licensed in State C. She can explain the reason to the client; what she cannot do is 'just process it through State A.'

The site fails on two independent grounds.

1. Wrong identifier. Federal law requires an MLO's own NMLS unique identifier on applications, solicitations, and advertisements - including websites and business cards. Displaying Summit's ID (1234567) in place of Priya's (9876543) does not satisfy the requirement. Both can be shown, but Priya's must be there and must be correct.
2. Misleading licensing claim. 'Licensed in State A' displayed on a site accessible to State B consumers, while soliciting State B business, is a misleading advertisement. Advertising a service she cannot lawfully perform in that state is also a state-law violation independent of the identifier issue.

Required changes:

• Add Priya's own NMLS ID, correctly, in a conspicuous place; keep the company's ID as well if the state requires the company identifier.
• Remove or rewrite any language implying nationwide authority; state the licensing jurisdictions accurately.
• Add the required company name and, where state law requires, the license number and state regulator reference.
• Stop any paid targeting of State B or State C consumers until the licenses exist.
• Add a retention process: advertising is subject to examination, so keep dated copies of what ran and when it was corrected.

Also worth flagging: the site should not promise 'low-rate' superlatives unless they can be substantiated, and the correction should be documented and reported to compliance rather than quietly edited.