Illinois confirms in writing that one person may hold a real-estate license and a mortgage loan originator license at the same time, and we found no rule against acting in both roles on the same purchase. IDFPR’s MLO FAQ states there is no prohibition in either Act and that a properly licensed person can perform services under each license, and it does not address one transaction with pay from both.
What Illinois requires
- Hold an active Illinois MLO license sponsored by an Illinois-licensed residential mortgage company, alongside the real-estate license.
- Disclose both roles and both forms of compensation to the buyer in writing.
What the rule says
There is no prohibition in either the Illinois Residential Mortgage License Act of 1987 or the Illinois Real Estate License Act of 2000 to the practice of simultaneously holding a mortgage loan originator license and real estate broker license.
The two professions are separate from each other and a properly licensed individual can perform services separately on any applicable Illinois conventional loan or real estate transaction. Federal statutory or regulatory limitations may exist and should be followed up with either the CFPB or HUD for FHA loans.
What we have not settled
The FAQ confirms holding both licenses. Acting in both roles on one transaction with pay from both is a favorable inference from it, not a stated rule, and the FAQ points to federal limits that apply on top.
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 Illinois
Coming soon. Licensing is underway in Illinois. Availability is subject to required approvals, and launch timing varies by state.