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Can a real estate agent be the loan officer on the same deal in Colorado?

Yes

By Gary Basin, co-founder of Ike · Reviewed

Yes. Colorado law directly addresses a person who is both the real-estate broker and the mortgage loan originator on one transaction, and permits it with a mandatory Dual Status Disclosure.

What Colorado requires

  • Deliver the Division of Real Estate Dual Status Disclosure within three business days after the loan application and obtain the borrower’s signature.
  • Disclose the conflict of interest and the compensation from each role.
  • Keep separate mortgage loan originator records.

What the rule says

Unless a mortgage loan originator complies with both subsections (2) and (3) of this section, he or she shall not act as a mortgage loan originator in any transaction in which: (a) The mortgage loan originator acts or has acted as a real estate broker or salesperson
C.R.S. § 12-10-724(1). Colorado dual status as a real estate broker, permitted on compliance with the disclosure and separation subsections, read October 15, 2026.
Before providing mortgage-related services to the borrower, a mortgage loan originator shall make a full and fair disclosure to the borrower, in addition to any other disclosures required by this part 7 or other laws, of all material features of the loan product and all facts material to the transaction.
C.R.S. § 12-10-724(2). Colorado dual status, the disclosure subsection, read October 15, 2026.
The Board prohibits individuals from acting as a Mortgage Loan Originator and a real estate broker, on the same transaction, unless they comply with the requirements set forth in this Rule. A. Dual status is a material fact to real estate transactions and must be disclosed to the borrower(s).
4 CCR 725-3, Rule 5.22. Colorado Division of Real Estate dual status disclosure rule, read October 15, 2026.
(e) Acting for more than one party in a transaction without disclosing any actual or potential conflict of interest or without disclosing to all parties any fiduciary obligation or other legal obligation of the mortgage loan originator to any party
C.R.S. § 12-10-713(1)(e) and (s). Colorado mortgage loan originator disciplinary grounds on conflicts and undisclosed compensation, read October 15, 2026.

What applies in every state

  • Both licenses must be active. The mortgage side is an individual MLO license, sponsored by a licensed mortgage company, with the SAFE test, 20 hours of education and a background check behind it.
  • Federal law sits above the state rule. RESPA Section 8 bars pay for a referral, and Regulation Z sets what a loan originator may be paid for. Compensation on the mortgage side is for origination work performed. The RESPA and referral-fee explainer walks through it.
  • The lender on the loan has its own rule. FHA permits the dual role since 2022. Conventional lenders decide file by file in writing.
  • The buyer keeps the right to choose any lender, and the disclosure says so.

Ike in Colorado

Coming soon. Licensing is underway in Colorado. Availability is subject to required approvals, and launch timing varies by state.

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This page is general information about state licensing rules, not legal advice, and not a statement by any regulator. Rules change. Confirm the current rule with the state regulator or a licensed attorney before acting on it.

Mortgage services are offered by Ike Mortgage LLC, a wholly owned subsidiary of Eichler Inc. Ike Mortgage LLC is preparing its mortgage license applications and is not yet licensed in any state. Its NMLS identifier will appear here when issued.

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