Who Needs to be Licensed as a Manager and Have a Supervisory Plan?

Consumer Services Director Cindy Fazio.

As noted in a previous newsletter, non-compliant or missing supervisory plans have become commonly identified findings during examinations. This newsletter article aims to provide a better understanding of Washington Administrative Code (WAC) 208-620-301 for the requirements of who needs to be licensed as a manager and have a supervisory plan when making residential mortgage loans in the State of Washington.

WAC 208-620-301(1) through (5) discuss which managers need to be licensed. These sections require that day-to-day operational managers of Washington mortgage loan originator (MLO), underwriting, and processing employees hold a proper license depending on the type of employees supervised.

The licensing requirements are as follows:

  • Day-to-day managers who supervise Washington MLOs must hold a Washington license.
  • Day-to-day managers who supervise underwriting and processing employees must hold a license, but the license can be from any state.

WAC 208-620-301(6) requires each licensed manager to maintain a written supervisory plan covering the following elements:

  • The number of employees supervised and their physical location.
  • How the supervisor will adequately supervise the employees if an employee is not in the same location as the supervisor.
  • The type and volume of work performed by the supervised employees.


1. What constitutes a day-to-day-to-day manager?

Day-to-day managers are supervisors who deal with everyday issues that arise in the course of business operations. They typically directly supervise employees in the normal course of business operations. Answering daily questions, scheduling work, and writing employee progress reports are examples of day-to-day supervision activities.

Which supervisor is considered the day-to-day manager depends on the type of engagement the manager has with the employee rather than just the position held on an organizational chart.

2. Must a manager maintain a separate supervisory plan for each employee supervised?

No, it is not required to have a separate plan for each employee. However, the plan or plans must incorporate all of the required elements of WAC 208-620-301(6). Please see this link for a supervisory plan model form.

3. Does the Department require use of a certain form for the supervisory plans?

No. However, the Department provides a sample model form for your use.

For questions or concerns, contact us at dcs@dfi.wa.gov or (360)-902-8703