What brokers need to know about making the move to non-del lending
As wholesale mortgage brokers continue to navigate the market, some are deciding to take a step beyond just being a broker and move into the lender space.
A growing trend involves brokers becoming non-delegated correspondent lenders. These brokers can close and fund loans in their own name, but rely on investors to make the underwriting decision.
At the National Association of Mortgage Brokers (NAMB) event in Las Vegas in October, a panel discussed the pros and cons of non-del lending and what brokers needed to know if they wanted to take that next step.
The panel included non-del lender Ross Miller (pictured top left), president of Miller Home Mortgage, Melissa Harris (pictured top middle), senior compliance partner at Strategic Compliance Partners, and Matt Coles (pictured top right), national sales manager for First Funding.
Coles said they have seen significant growth in the space in 2025 for several reasons.
“We are seeing an explosive growth in the non-delegated space,” Coles said. “It’s kind of like threefold. One is the originator. Everything starts and ends with the originators. The originator growth that we've seen in the last several years, and people are moving from the retail channel, distributed retail channel, into the TPO world, they're going to want to go back to the way that they were doing business before.
“It's also brand building. Everyone has a brand nowadays. Social media allows us to build out a brand. The idea of having your name on the docs, the place, and the ownership of everything from start to finish is really driving a lot of the business. Third, it's really the great investors that we're all working with who are all driving this business as well.”
Having more control
Miller, who is a non-del lender, said part of the reason he wanted to pursue the opportunity to move into the space was to have more of a say in how the process flowed.
“I think it gives the loan officer and the non-delegated company a lot more control over the process,” Miller said. “It will let you work faster, more efficiently, and you will come across as much more of a loan expert to your customer. When you're building your brand, you'll look more professional compared to somebody else who always maybe is going back, saying, ‘I can't do something, it's on somebody's desk.’
“You control the time, and you control the speed at which it's going. You're able to set those expectations with your realtor partners, with your customers, and then you're able to deliver on those, and it makes you look great. Then you get more referrals through doing it that way.”
With the help of First Funding, Miller was able to make the move into the non-delegated space. He said he had some concerns, but looking back, he wishes he had jumped at the chance before he eventually did.
“I would have done it sooner,” Miller said. “When I first did it as a small company, I was a little concerned about some things. I actually got aligned with First Funding, and it took me about a year to really jump in and start doing it regularly. But it's just like anything else in terms of being in the mortgage business, once you start doing it, it's the same process over and over again.”
He said there are a few things that he’s still working through as he continues to improve as a non-del lender.
“I'm working on doing more hybrid closings, how to expedite the wires, how to expedite the post-closing piece,” Miller said. “By the way, we haven't talked about post-closing on a non-del loan, which is slightly different than when you do a brokered loan. I'm working on expediting that so that we get paid sooner. So it's always a little bit of a moving ship.”
Keeping compliance in mind
Of course, for brokers considering the move into the non-del space, understanding compliance needs up front is critically important. Harris reminded everyone that there is much more reporting required when moving to non-delegated.
“We all know compliance is complex, and the switch from broker to non-del, from an operational standpoint, there is a lot more that you guys need to know about,” Harris said. “Most of the time with most of the lenders that you guys do business with will be responsible for initial disclosures, closing disclosures, pre-disclosures, even the content, the fees, etc., on those disclosures.
“Your mortgage call reports, MCRs, they get a lot more intense from a reporting standpoint. You're reporting more information, more data points. Your financials will now be reported quarterly instead of annually.”
Kimber White, President of the National Association of Mortgage Brokers, outlines how NAMB’s new Elevate mentorship program and ongoing advocacy on LO comp reform will strengthen broker education and collaboration across the industry.https://t.co/gx8r9of4ss
— Mortgage Professional America Magazine (@MPAMagazineUS) November 12, 2025
Another factor brokers will need to consider is that quality control reviews will now be required post-close.
“In the broker world, quality control doesn't necessarily exist from a traditional QC post-close perspective,” Harris said. “When you're non-del, that happens. That's required now. So that means you're contracting with a third-party vendor to perform those post-close, QC reviews.”
Harris stressed to brokers considering the move to partner with a compliance company to help guide them through the steps and, hopefully, cut off any potential problems before they start.
“I threw a lot of stuff at you guys, not to necessarily scare you, but to let you know that realistically, it is a drastic change going from broker to non-del,” Harris said.
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