Following NMLS changes that went live on April 18, 2026, CSBS and NMLS materials recommend updating affected MU2 and MU4 records by August 31, 2026 ahead of renewals. The changes include revised disclosure questions, redesigned employment reporting, employment gap entries, and company-managed work contact fields.
What changed
NMLS changed key individual and control-person data fields earlier in 2026 and set an August 31, 2026 target for updating impacted records. By late July 2026, firms were in the active cleanup period before renewal season.
Compliance perspective
Companies should identify all impacted MU2 and MU4 records, assign record owners, and complete updates before the August 31 deadline. Delays can create renewal friction and inconsistent employment or disclosure histories across state filings.
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