I read the cite. 1026.36(f)(3)(iii) commentary mentions the training must be sufficient to ensure the loan originator has the knowledge of State and Federal legal requirements. My hangup is on the word "State". My understanding is that if we are a National chartered FI, then there are no "State" requirements for us there because we are not regulated by the State. Concur?
And as for Federal regulations, do they mean the periodic training we give them on topics such as ECOA, TILA, RESPA? Or is it only specific Reg Z training they are concerned with?