Commercial Mortgage Broker in Tennessee: Licensing, Markets & Resources

Tennessee's mortgage broker licensing statute is written around residential lending, which is the single most important fact for anyone brokering commercial debt in the state. T.C.A. Section 45-13-105(15) defines mortgage loan broker by reference to a residential mortgage loan, and Section 45-13-105(25) limits a residential mortgage loan to a loan primarily for personal, family, or household use secured by a dwelling or by residential real estate on which a dwelling is or will be constructed (Source: Tennessee Code Annotated, Title 45, Chapter 13, published by the Tennessee General Assembly). Section 45-13-201(b)(1) then lists an explicit exemption for a person engaged solely in commercial real estate lending or a person providing financing on property that is not and is not intended to be owner-occupied by the person receiving the financing. A broker arranging a permanent loan on a Nashville industrial building or an SBA 504 loan on a Memphis medical office is generally not doing what Chapter 13 regulates. A broker who also touches residential product is. Confirm your own facts with the Tennessee Department of Financial Institutions before you treat yourself as out of scope.

Tennessee Licensing Requirements for Mortgage Brokers

The Tennessee Department of Financial Institutions (TDFI) is the regulator. It administers the Tennessee Residential Lending, Brokerage and Servicing Act, codified at T.C.A. Title 45, Chapter 13. Tennessee participates in the Nationwide Multistate Licensing System and Registry (NMLS) for these licenses, and TDFI publishes the Tennessee Mortgage License Requirements Checklist inside NMLS.

Why the Residential Scope Matters

Read the definitions section before the licensing section. Tennessee's mortgage loan broker definition in T.C.A. Section 45-13-105(15) is tied to residential mortgage loans, and Section 45-13-105(25) limits that term twice over: the loan must be primarily for personal, family, or household use, and it must be secured by a dwelling (as defined in Section 103(v) of the federal Truth in Lending Act) or by residential real estate on which a dwelling is or will be constructed.

Commercial property debt for a business purpose fails both prongs. That is the structural reason commercial-only brokers in Tennessee are generally not required to hold a Chapter 13 license. The point is reinforced by T.C.A. Section 45-13-201(b)(1), which lists specific exemptions from the licensing requirement, including a person engaged solely in commercial real estate lending and a person providing financing on property that is not and is not intended to be owner-occupied by the person receiving the financing (as added by Public Chapter 228, 2011). The analysis remains fact-specific. A cash-out refinance on a small residential rental portfolio, a loan to an individual secured by a house that funds a business, or a mixed-use deal where the collateral is predominantly residential can each pull an engagement back toward the statute.

If You Broker Residential Loans Too

Many commercial brokers in Tennessee came out of residential and still write some. If that is you, the Chapter 13 requirements apply to that side of the book. The figures below come from the statute as published by the Tennessee General Assembly. Fees set by rule change over time, so treat these as the statutory baseline and verify current amounts inside the NMLS TN checklist.

Mortgage loan servicers carry a separate $200,000 bond under T.C.A. Section 45-13-204(b). Application fees, per-originator fees, and other administrative amounts are set by rule and by NMLS and should be verified against the current TN checklist before filing.

For the multistate picture, see the guide to mortgage broker licensing by state and the broader guide to licensing and regulatory requirements for commercial real estate mortgage brokers. Both are starting points for research, not substitutes for a call to TDFI.

Business Items That Are Not Licensing Items

Entity registration with the Tennessee Secretary of State, local business tax registration where applicable, and a signed written fee agreement before you shop a deal are ordinary operating requirements, not mortgage licensing. If your engagement includes selling or leasing property rather than arranging debt, that is a separate question under the Tennessee Real Estate Broker License Act of 1973 and belongs with the Tennessee Real Estate Commission.

Tennessee's Major Commercial Real Estate Markets

Tennessee's deal flow concentrates in four metros, with a working set of secondary markets that support bank, credit union, and SBA volume more than institutional capital.

For metro-level detail, see the pages on commercial real estate loans in Nashville, commercial real estate in Memphis, and commercial real estate in Chattanooga.

The Tennessee Lending Landscape

Tennessee has deep regional bank competition and a full stack of institutional capital in Nashville and Memphis. Pinnacle Financial Partners and FirstBank are headquartered in Nashville. First Horizon Bank (the former First Tennessee) is headquartered in Memphis and remains a meaningful CRE lender across the state. Regions Bank has a large Tennessee footprint. Truist, Fifth Third, Bank of America, JPMorgan Chase, and U.S. Bank all compete on larger transactions in Nashville, Memphis, Chattanooga, and Knoxville. Community banks and credit unions fill the small-balance and secondary-market gap.

Fannie Mae and Freddie Mac are the dominant permanent debt sources for stabilized multifamily statewide, and Tennessee's population growth and absence of statewide rent control support agency rent growth assumptions. See the Fannie Mae multifamily guide and the broker guide to multifamily finance for program mechanics, along with the glossary entries on Fannie Mae multifamily and Freddie Mac multifamily.

CMBS conduit lenders concentrate on Nashville, Memphis industrial, and larger Chattanooga and Knoxville deals, generally above $2 million to $5 million depending on the shop, and generally on a non-recourse basis. See the glossary entry on CMBS for structure. Life insurance companies take the best-located, best-leased industrial along the I-40, I-24, I-65, and I-75 corridors, plus grocery-anchored retail with strong anchor credit; see the guide to life company loans. HUD is active on workforce, affordable, and senior housing across the state, using the HUD 223(f) refinance program and the HUD 221(d)(4) construction and substantial rehabilitation program (see the HUD multifamily guide for eligibility mechanics). Debt funds and bridge lenders cover value-add multifamily, industrial repositioning, and hotel renovation using bridge loans, often paired with mezzanine financing or preferred equity higher in the stack. See the guides to bridge loans and bridge to perm financing for multifamily.

SBA volume is a Tennessee strength. The SBA 504 loan and the SBA 7(a) loan both see steady use on owner-occupied deals across hospitality, healthcare practices, manufacturing, and franchise food service. See the SBA loans guide for eligibility mechanics, including the owner-occupancy thresholds that trip up first-time SBA sponsors. New construction loans on ground-up projects are dominated by regional banks with occasional debt fund participation on larger multifamily.

What Brokers Need to Know About Tennessee Commercial Real Estate

Nashville Multifamily Supply

Nashville delivered one of the deepest multifamily pipelines in the country between 2023 and 2025. Rent growth softened in the core submarkets during that absorption period, and lenders sizing new deals want realistic trend rent assumptions rather than 2021 through 2022 peak comps. Pre-size with the DSCR calculator before you shop.

Memphis Logistics and BlueOval City

Memphis industrial underwriting turns on tenant credit tied to the FedEx World Hub, the Port of Memphis, and the broader I-40 and I-55 logistics network. The Ford Tennessee Truck Plant in Haywood County (the campus originally announced as BlueOval City for electric vehicle manufacturing; Ford shifted to gas-powered truck production in 2024 after the Ford-SK On joint venture dissolved) is reshaping the West Tennessee industrial pipeline, with Tier 1 and Tier 2 automotive suppliers driving speculative and build-to-suit development along the I-40 corridor. Lenders pay close attention to which contract a tenant serves and how long the lease runs relative to the underlying supply agreement.

Chattanooga Automotive Base

Volkswagen Chattanooga Assembly (including the ID.4 electric SUV program) anchors a Tier 1 and Tier 2 supplier base across Hamilton and adjacent counties. Chattanooga industrial demand also draws on Amazon fulfillment, TVA, and the EPB municipal gig fiber network that has supported technology and data-adjacent tenancy.

Knoxville and Oak Ridge

Knoxville's economy carries University of Tennessee student housing demand, medical office demand tied to Covenant Health and UT Medical Center, and a specialty research and industrial component from Oak Ridge National Laboratory. Student housing lenders look at distance to campus and pre-leasing velocity; medical office lenders look at health system affiliation.

Franchise Tax and Excise Tax

Tennessee imposes a franchise tax and an excise tax on entities doing business in the state (administered by the Tennessee Department of Revenue). The franchise tax applies to the greater of Tennessee net worth or the book value of Tennessee real and tangible property, and the excise tax applies to net earnings. This shows up in pro formas as an operating expense line and in entity structuring decisions on new sponsor deals.

Metrics Lenders Size To

Tennessee deals get sized on the same metrics as anywhere else. DSCR drives most bank and agency sizing, with typical minimums in the 1.20x to 1.25x range depending on lender, property type, and structure. Loan-to-value supports the leverage side, and cap rate supports the valuation side. Pre-size using the DSCR calculator and the commercial mortgage calculator so your term sheet expectations survive the first lender call.

Tennessee Commercial Real Estate Lending Outlook

Tennessee remains one of the more active Sunbelt states for CRE debt because the same factors driving in-migration (no state income tax, right-to-work status, business-friendly regulatory posture) also drive tenant demand. Multifamily absorption has held up despite the 2023 through 2025 Nashville supply wave, and West Tennessee industrial has a long runway tied to the Ford Tennessee Truck Plant (formerly BlueOval City) supplier ecosystem. Deep bank competition keeps small-balance and community deals well-served, while national capital sources treat Nashville and Memphis as institutional markets.

By property type, the deepest lender pools in Tennessee are in bulk industrial (Memphis, Nashville, Chattanooga), stabilized multifamily (statewide, agency-led), and medical office (all four major metros). The tightest are commodity Class B office outside Franklin and downtown Nashville, and hospitality outside the primary tourism nodes. Property-type guides worth pulling: industrial, retail, office, and hospitality.

Frequently Asked Questions