No. Regulation Z simply requires that if a loan originator under Reg Z fits the description of a mortgage loan originator under Reg G, he or she must be registered or licensed under the SAFE Act if required by Federal or state law to do so. Remember that the the definition of loan originator is generally more inclusive than the definition of a mortgage loan originator, so a lender is very likely to have loan originators on staff who don't have to register as mortgage loan originators under Reg G.
Then 1026.36(f) goes on to impose a training requirement for all loan originators who are not licensed mortgage loan originators under state law. For most banks, that means all loan originators, since any of its mortgage loan originators would be registered, not licensed.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8