Because mortgage brokers originate 70% of all residential mortgage loans in the subprime market, regulating broker conduct by way of licensing statutes has been an important component of states’ efforts to combat predatory lending. Recently, however, proposals have been introduced in Congress to license mortgage brokers at the federal level. Professor Wilson’s article analyzes those proposals from three perspectives. First, the article demonstrates the proposals’ lack of utility by evaluating them according to a taxonomic hierarchy of regulatory mechanisms found in existing state licensing statutes. Second, the article establishes the preemptive effect the proposals would have on state level licensing statutes, including exposing a strategy Professor Wilson labels “stealth preemption.” Third, the article identifies a hermeneutical bias in the federal proposals that has the unfortunate ramifications of sending undesirable ethical signals to mortgage brokers and of limiting the range of ideas that are considered by legislators and policy makers.