We found no Missouri rule against a real-estate agent acting as the mortgage loan originator on the same purchase. Both the mortgage and the real-estate side ask for disclosure and nothing more.
What Missouri requires
- Disclose both roles and both forms of compensation to the buyer in writing.
- Hold an active Missouri MLO license sponsored by a licensed mortgage company.
What the rule says
Each residential mortgage loan broker shall maintain, in the state of Missouri, at least one full-service office with staff reasonably adequate to efficiently handle all matters relating to any proposed or existing home mortgage
Acting for more than one party in a transaction without the knowledge of all parties for whom he or she acts, or accepting a commission or valuable consideration for services from more than one party in a real estate transaction without the knowledge of all parties to the transaction
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.