Ask for the property state on the lead form, route the lead only to a loan officer licensed in that state, and hold any quote or application until that loan officer is assigned. GoHighLevel can branch on the state field and assign the opportunity automatically. The bottom line: licensing is state by state, so a lead assigned to the wrong loan officer is a compliance problem on day one, not a sales problem.
What the SAFE Act requires
The SAFE Act requires every state to license anyone who takes a residential mortgage loan application or offers or negotiates the terms of a residential mortgage loan for compensation or gain, and an AAPL summary says that means being licensed as a mortgage loan originator in the state where the property is located. NMLS documentation says originators must maintain their license in each state in which they conduct loan origination activity. A LoanOfficer.ai guide adds that there is no reciprocity between states and that sponsorship must be filed by a company licensed in each state. A Wolters Kluwer summary notes that most state licensing laws require the NMLS identifier on solicitations, websites, and business cards. The practical result is that your routing needs a table of which loan officers are licensed where.
A routing table
| Property state | Loan officers licensed there | If none is available |
|---|---|---|
| Florida | Dana, Jordan | Hold the lead and assign the next day, or refer out |
| Georgia | Jordan, Sam | Hold the lead and assign the next day, or refer out |
| Texas | Sam | Refer out if Sam is unavailable for more than a day |
| Any other state | None | Reply that the brokerage is not yet licensed there, and do not discuss terms |
Keep the table in one place that compliance owns, and update the workflow when a license is added or lapses. The names above are an example.
What the first reply may say
Before a licensed loan officer is assigned, the reply should do three things: thank the lead, say a licensed loan officer will be in touch, and ask for nothing beyond what the form collected. Do not quote a rate, discuss terms, or take an application from someone who is not licensed in the property state, and check your state's rules on what an unlicensed assistant may say.
Build it in HighLevel
- Add a required property state dropdown to every lead form and keep it as a contact field.
- Create a workflow that starts on form submission and uses an If/Else branch for each state in your table.
- In each branch, use the Assign to User action to assign the contact to the licensed loan officers for that state, and confirm in your account how rotation among users is set.
- Add the tag with the state, such as Property state FL, so reports show volume by state.
- In the final branch for unlicensed states, send the no discussion reply and create a task for compliance to review the referral.
- Create a task for the assigned loan officer due in 5 minutes during business hours, and an escalation to a backup in 30 minutes.
- Review the routing table every quarter and after every license change.
The reply, written out
Assigned: Hi Alex, this is Jordan at [Brokerage], NMLS [number]. I am the loan officer for your area and I received your request. Do you have a few minutes today, or would a call tomorrow be better? Reply STOP to stop messages. Not licensed: Thanks for contacting [Brokerage]. We are not able to help with loans in that state at this time. Reply STOP to stop messages. The second message gives no terms, no rates, and no referral promise.
Worked example
A brokerage licensed in 3 states that gets 150 leads a month, with 10 percent from states where it is not licensed, would receive 15 such leads a month (150 times 0.1). The routing sends each a polite no discussion reply and a compliance task, and keeps those 15 out of the loan officers' queues. The 10 percent is an assumption, so replace it with your own lead mix.
When a lead's state changes
A buyer may start in one state and end up buying in another, or move during the search. If the property state changes, update the field, and the workflow reassigns the opportunity to a loan officer licensed in the new state. Add a task for the original loan officer to hand off the file with a short note. A lead who is passed along cleanly stays a lead, and one who is dropped usually goes to a competitor.
Referring a lead out
When the brokerage is not licensed in the property state, a referral to a licensed broker may be possible, but referral fees and arrangements have their own rules under RESPA and state law, so route the decision to compliance. The first reply should only say that you cannot help in that state, and any referral should be a separate, reviewed step.
How this was handled before
A lead came in through a shared inbox, and whoever was online replied. Sometimes the person was not licensed in the property state, and the first message already crossed a line. Branching on the state field puts the rule before the reply.
What to measure
Track leads by property state, leads routed to a licensed loan officer within 5 minutes, leads from unlicensed states, and time to first call. The number of replies sent by an unlicensed person should be zero.
Questions people ask
Do mortgage loan officers need a license in each state?
Under the SAFE Act, yes. An originator must be licensed in the state where the property is located and in each state where they originate loans, and there is no reciprocity between states.
What should a broker reply to a lead from an unlicensed state?
Say the brokerage cannot help with loans in that state, and do not discuss terms or rates.
Does an NMLS number go in marketing messages?
Most state licensing laws require the NMLS identifier on solicitations and advertisements, so check your state's rule for texts.
You can start a GoHighLevel account here and build the state routing, and see user assignment and tasks in our capabilities demo.