We have an employee that was previously registered at another institution; however, he never changed his records to our bank with the NMLSR. He's been here over 2 1/2 years. We discovered that he handled a HELOC this year and I'm wondering if we have an issue with the de minimis rule as he does not meet the first prong which says that the employee must never have been registed or licensed through the NMLSR as a MLO.
What are the consequences of this if this is a problem? BTW, the only I know this is because I worked with him at the other institution.
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TryingToComply
CRCM