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An applicant for an MLO license was convicted of felony assault nine years ago. He has no other record. Under the SAFE Act's minimum standards, does the conviction bar him?
An applicant must not have been convicted of a felony during the 7 years before the application, or at any time if the felony involved fraud, dishonesty, breach of trust or money laundering (12 U.S.C. 5104(b)(2); 12 CFR 1008.105(b)). An assault conviction nine years ago is outside the 7-year window. The regulator still assesses character and fitness separately. Source: 12 U.S.C. 5104(b)(2); 12 CFR 1008.105(b) (as at 11 Oct 2026).
Treating every felony as a lifetime bar.
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