Washington State officials fined a global mortgage services provider for unlicensed activity, pointing to the potential risks posed to lenders by third-party vendors amid still-ongoing consumer regulatory scrutiny.  

3N Performance, a technology services advisory and workforce solutions outsourcing firm, agreed to a consent order and a $75,000 fine from the Washington Department of Financial Institutions in August. Regulators found 3N violated Washington's consumer loan act, after the company's staff was found to have performed mortgage processing and underwriting activity, despite the company never holding a proper state license. 

Between late 2023 and mid-2025, 3N acted as a third-party processor or underwriter on 1,803 mortgages secured by Washington properties, the department said. In signing the order, 3N noted its understanding of the law and the accusations and said it would cease and desist such activity without proper state credentials.   

3N had not responded to an inquiry from National Mortgage News prior to article publication. While the penalty hit 3N and not its business customers, vendors falling out of compliance pose a risk in making the loans in question subject to potential buybacks. 

The company also applied for a Washington State mortgage broker license in March 2025, which is currently pending. The consent order would have no bearing on the application but officials clearly spelled out to 3N the limits of what would be permissible if the license is granted. 

"It is further agreed that respondent understands that it can only conduct third-party processing activities under a mortgage broker license and would need to obtain a consumer loan company license before conducting underwriting activities in Washington," the order said.    

Based in Charlotte, North Carolina, the company, which was formerly known as OPX America before rebranding to 3N Performance in early 2025, provides services to mortgage, consumer banking and insurance industries. Outside of its Charlotte headquarters, 3N operates out of offices in three other U.S. locations, as well as in India and the United Arab Emirates. 

The reach of state enforcement

The latest order serves as another example of the strict regulatory environment still existing in several states, even as federal laws loosen in the current Trump administration. Washington has emerged as one of the jurisdictions most willing to pursue and penalize companies for consumer lending violations. 

In a July consent order, Washington DFI issued a similar $75,000 fine against West Capital Lending for a host of infractions, including several instances of unlicensed origination activity and failure to properly prepare or maintain supervisory plans and annual reports earlier this decade. The department also found West Capital noncompliant in not holding required surety bond coverage for 2023 and 2024 and using prohibited advertising terms in its marketing. 

Earlier this year, state regulators also announced it planned to go after Newrez for alleged violations of consumer protection laws from 2021 to 2026 related to its servicing operations, including improper escrow maintenance and incorrect onboarding of loans. Officials proposed a $4.2 million fine, which would be one of the largest ever imposed by Washington regulators.