3.2 Annual Renewal Cycle, CE Deadlines, & Reinstatement

3.2 Annual Renewal Cycle, CE Deadlines, & Reinstatement

Quick Answer: Texas RMLO renewal runs November 1 through December 31. The originator must complete 8 hours of NMLS-approved continuing education each year (7 TAC § 55.108; Finance Code § 180.060). NMLS will not accept a renewal request until the course provider posts completion, and providers have 7 calendar days to post—so finish CE well before December 31. A timely request, combined with Approved / Approved-Deficient / Approved-Conditional status and a renewed sponsorship, lets origination continue after January 1. Miss midnight December 31 and the license expires January 1. Reinstatement runs January 1 through February 28 (February 29 in a leap year), is treated as an application, bars origination until SML approves, and costs 150% of the base license fee.

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Renewal is a license application, not a courtesy checkbox

Under 7 TAC § 55.103(a), a license may be renewed on three things happening together: (1) timely submission of a completed renewal request in NMLS with all required fees; (2) SML’s determination that the originator continues to meet the minimum requirements for licensure, including Finance Code §§ 157.012(c), 157.015(g), and 180.055; and (3) completion of the continuing education required by Finance Code § 180.060 and 7 TAC § 55.108, as reflected in NMLS. Section 55.103(b) treats the renewal request as a license application subject to the Chapter 55 application rules. This is why a “I meant to click renew” story does not preserve origination authority after December 31.

SML’s FAQ fixes the calendar in operational terms. The annual renewal period is November 1 to December 31. If the originator submitted a renewal request during that window, the license should continue into the new year if the originator meets the requirements to maintain the license and there are no active license items that would prevent renewal. NMLS license status—not a paper card—controls origination. If the license is properly sponsored and is in an Approved, Approved-Deficient, or Approved-Conditional status on and after January 1, the originator may continue to originate. If the originator did not request renewal before midnight December 31, the license expired on January 1 and origination is prohibited until a later reinstatement or new license is approved.

Eight hours of NMLS-approved CE, posted before you can even click renew

7 TAC § 55.108(d) requires an originator to complete, on an annual basis, continuing education and coursework approved by NMLS in order to renew the license, as provided by Finance Code § 180.060 and § 55.103. SML’s FAQ states the hour count in plain language: a license holder must complete 8 hours of continuing education annually through an NMLS-approved course provider.

Finance Code § 180.060 incorporates the federal SAFE Act floor. Under 12 U.S.C. § 5105(b), a State-licensed loan originator must complete at least 8 hours of NMLS-approved education, which must include at least 3 hours of federal law and regulations, 2 hours of ethics (including fraud, consumer protection, and fair lending), and 2 hours related to lending standards for the nontraditional mortgage product marketplace. Credit is granted only for the year in which the course is taken, and the originator may not take the same approved course in the same or successive years to meet the annual requirement (12 U.S.C. § 5105(b)(3)). An NMLS-approved instructor may receive CE credit at the rate of 2 hours of credit for every 1 hour taught. Texas does not replace that federal floor with a different hour total; SML simply requires the 8 NMLS-approved hours to appear in NMLS before renewal will process.

The posting mechanic is the trap. SML’s FAQ warns that if the originator is deficient in continuing education as determined by whether a completion record exists in NMLS, the originator will be unable to submit a renewal request. The Department cannot override that system block. Course providers have 7 calendar days to submit the record of course completion to NMLS. Completing a course at 11:00 p.m. on December 31 does not create a completion record in NMLS that night. Independent OpenExamPrep teaching for this overlay therefore treats “finish CE well before December 31” as an operational requirement, not optional courtesy.

For reinstatement, late CE is required as applicable. If the originator never obtained a posted 8-hour record for the year, SML still expects NMLS-approved CE to be completed and posted before it will approve a reinstatement request. The same 7-day provider posting delay applies. Do not assume that paying the reinstatement fee substitutes for a missing CE transcript.

Sponsorship renewal is a second clock running in parallel

SML’s FAQ includes a sponsorship warning inside the January 1 origination question. In order for sponsorship to remain in place, the entity sponsoring the license (mortgage company or mortgage banker) must also renew its license or registration. If the company does not renew, the individual’s license can lapse into Approved-Inactive even though the originator personally requested renewal and completed CE. Inactive status precludes origination. The individual’s timely MU4 renewal does not rescue a dead company license.

The same logic applies in reverse. An originator who renews while Approved-Inactive—for example, between jobs—keeps the individual credential alive but still may not originate until a new sponsorship is accepted. Renewal preserves eligibility. Sponsorship supplies authority.

Approved-Deficient after a renewal request

SML’s FAQ explains that Approved-Deficient is assigned when SML determines there are pending issues that are relatively minor and should not prevent approval in the interim. That status allows origination in Texas, but the originator must resolve the pending issues to avoid disciplinary action and because unresolved items will also prevent renewal. 7 TAC § 55.103(c) adds the Commissioner’s discretion to approve a renewal with deficiencies deemed relatively minor, assign Approved-Deficient, and treat the license as a conditional license. The originator must then resolve the deficiencies within 30 days after the date the license is approved, unless the Commissioner grants an extension. Failure to timely resolve the deficiencies is grounds to suspend or revoke the license. Approved-Deficient is therefore permission to keep working while you finish the punch list—not a free pass to ignore SML.

Expiration, reinstatement, and the 150 percent fee

If renewal is not requested by midnight December 31, SML’s FAQ is categorical: the license expired on January 1 and remains expired until renewal is requested and the request is processed and approved by the Department. That later request is treated as an application for reinstatement. 7 TAC § 55.103(d) applies the renewal section to an individual seeking reinstatement of an expired license assigned the NMLS status “Terminated - Failed to Renew” during the reinstatement period described by Finance Code § 157.016. The originator cannot originate while that application is pending. SML notes that processing takes time, which is why submitting during November 1–December 31 matters.

SML’s FAQ sets the reinstatement window as January 1 to February 28 (February 29 if a leap year) following expiration. After that window, 7 TAC § 55.103(d) is explicit: an originator license cannot be renewed beyond the reinstatement period. The individual must apply for a new license and comply with all current requirements and procedures governing issuance of a new license.

The price of missing the ordinary renewal window is statutory. SML’s September 1, 2026 fee-schedule announcement states that, in accordance with Texas Finance Code §§ 156.2081 and 157.016, licensees that do not timely renew and seek reinstatement are charged a fee equal to 150% of the base license fee. That reinstatement surcharge applies to individual RMLOs and to residential mortgage loan companies (including mortgage companies, independent contractor loan processor or underwriter companies, and credit union subsidiary organizations). SML’s FY2027 announcement also states that license and registration fees remain unchanged for FY2027—no across-the-board increase to ordinary application or renewal fees. The way to avoid the 150% reinstatement fee is to renew in NMLS on or before December 31.

Five consecutive years without a valid license: retake the UST

A long lapse is not cured by reinstatement fees. Under 12 U.S.C. § 5104(d)(3)(D), a State-licensed loan originator who fails to maintain a valid license for a period of 5 years or longer must retake the test, not taking into account any time during which the individual is a registered loan originator. Texas implements that federal test standard through Finance Code § 180.057 and 7 TAC § 55.108. After five consecutive unlicensed years, paying 150% and filing before February 28 is not enough: the individual must pass the current National Test with Uniform State Content (UST) again as part of qualifying for a license. Time spent as a depository-institution registered originator does not count toward the five-year lapse, because the federal provision excludes registered-originator time from the gap calculation.

A December close that survives NMLS

Confirm the 8-hour NMLS-approved record is posted before opening the renewal workflow. Leave at least the 7-day provider posting period before December 31. Confirm the sponsoring company or banker is also renewing. If status is Approved-Deficient, originate only while that status remains in force and resolve the punch list, because unresolved items block the next renewal. Miss December 31, stop originating on January 1, complete late CE as applicable, file by February 28/29, pay 150% of the base license fee, and wait for SML approval. After that window, file a new application. After five consecutive unlicensed years, retake the UST.