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#1869217 - 11/07/13 02:27 PM CE for federally register MLO?
vagilto Offline
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Joined: Oct 2013
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Are Continued Education required to renew a federally registered MLO?

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S.A.F.E. Act Forum
#1869299 - 11/07/13 03:41 PM Re: CE for federally register MLO? vagilto
rlcarey Online
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rlcarey
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Galveston, TX
No. However there are going to be training requirements for loan originators come January under Regulation Z.
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#1880736 - 12/20/13 07:48 PM Re: CE for federally register MLO? vagilto
Oursisnottoreasonwhy Offline
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Oursisnottoreasonwhy
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Central Illinois
See 1026.36(f)(3)(iii)

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#1899465 - 02/24/14 08:42 PM Re: CE for federally register MLO? vagilto
fct Offline
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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?

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#1899497 - 02/24/14 09:11 PM Re: CE for federally register MLO? vagilto
rlcarey Online
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rlcarey
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Galveston, TX
1. You have to comply with State law unless the law specifically falls under preemption authority.

2. All of the above.
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#1899523 - 02/24/14 09:50 PM Re: CE for federally register MLO? vagilto
fct Offline
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Thanks rlcarey. Is it me, or does it seem like "periodic" now sounds like "annual" since they renew every year?

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#1899555 - 02/24/14 10:56 PM Re: CE for federally register MLO? vagilto
rlcarey Online
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rlcarey
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Posts: 83,393
Galveston, TX
Most banks cover these topics in one form or another on an annual basis with loan officers anyway, I would hope.
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