did the de minimus go away? or can employees not registered still originate up to 5 a year

It was my understanding they could still originate up to 5.

i was just reviewing the cfpbs 2013 loan originator rule guide and couldnt find any mention of the de minimus rule but also there was no mention in the summary of changes that the rule was eliminated so i thought i would ask.

we recently had an MLO leave at oe of our branches and an unregister commercial loan officer will be handling a closing so i wanted to make sure this was still in line with the rules

I'm not sure closing the loan even falls within the definition of a MLO???

yes i would agree just closing isnt within the definition, but the plan, in the mean time, is for this individual (unregistered Commercial LO) to handle loan requests that come through the door

this location is in a small enough community that the app numbers would suggest that they will never reach five assuming we get another lender in the location soon enough

The de minimus rule is still in effect for registration under the Safe Act. 1007.101(c)(2)

There is no de minimus under Regulation Z if they are a mortgage originator.

Whether they would have to be State licensed under the Safe Act is a State law issue. There may or may not be a de minimus.