Have an existing loan (prior to the SAFE Act) customer would like to do a short term change in terms to pay interest only for 3 months. The loan officer is not a registered MLO. Can she complete this cahnge in terms with out counting towards the 5 per year de minimus exception?

Appendix A to Part 1007—Examples of Mortgage Loan Originator Activities


(2) Taking an application does not include any of the following activities performed solely or in combination:

(vi) Receiving information in connection with a modification to the terms of an existing loan to a borrower as part of the covered financial institution's loss mitigation efforts when the borrower is reasonably likely to default.