An individual who is a loan processor or underwriter must maintain a state originator license...

An individual who is an independent contractor and performs loan processing or underwriting activities must maintain a state originator license if they collect, receive, or distribute information in connection with making a credit decision. This is because independent contractors are not considered supervised employees, and their work directly impacts the loan approval process.

In contrast, employees of a mortgage lender who perform clerical duties (A) under supervision do not need a state license, nor do those who do not interact with consumers (B).

References:

SAFE Act, 12 USC §5101

NMLS Licensing Guidelines for loan processors and underwriters