1.Annual Renewal Requirements

Beginning November 14, 2025, all MLOs—regardless of active or inactive status—must renew their licenses each year between November 1 and December 31. Any license not renewed by midnight on December 31 will expire automatically.
Renewal requires timely payment of fees and proof of completion of the NMLS-approved continuing education (CE)for that year. Even inactive licensees must complete CE annually to remain eligible for reactivation.

Colorado emphasizes that MLOs must complete both steps of renewal: (1) renewal through NMLS and (2) through the Colorado Division of Real Estate’s online portal. Completing one without the other can still lead to expiration.

2.Defined Reinstatement Window

From January 1 through February 28, expired licensees may reinstate by paying a higher fee (1.5 times the standard renewal cost) and fulfilling all CE requirements. After February 28, reinstatement is no longer available; the individual must apply as a new licensee, completing fingerprinting, background checks, and all state-specific education and testing.

The new rules clarify that reinstated licenses are considered continuous with the prior year’s license, whereas re-applications after February 28 are treated as brand-new licenses, resetting the license history.

3.Inactive License Clarifications

Inactive MLOs may not engage in origination activity but must continue to renew annually and complete CE. Failure to do so will result in expiration and subject the licensee to the same reinstatement or re-application requirements as active MLOs.

4.Implications for Companies and Compliance Teams

Mortgage companies employing Colorado-licensed MLOs should begin preparing for these changes now:

♦  Audit license rosters to verify each MLO’s active/inactive status.
♦  Confirm renewal readiness by mid-October each year to avoid end-of-year delays.
♦  Communicate reinstatement rules to staff—late renewal fees and reinstatement procedures will now be strictly enforced.
♦  Update training materials to reflect the clarified CE and renewal requirements.

5.Bottom Line

The Division’s update under 4 CCR 725-3 provides greater regulatory clarity and underscores the state’s emphasis on maintaining qualified, continuously educated originators. With the rule taking effect November 14, 2025, lenders and compliance departments should begin integrating these changes into their renewal tracking systems and communication calendars.