If we have not been offering consumer residential mortgage loans and are considering it at this time but feel like we will not have more than 5 requests would you have the lenders who may offer the product register or wait until we near the number 4 loan for the lender? We are a small community bank with branches in a metro area and branches in two rural communities. I'm looking for some guidance please.
Thanks

You can certainly wait to register an LO until they reach the threshold; BUT you must a have a tracking mechanism in place to 1) demonstrate that an LO qualifies for the de minimis exception and 2) determine when the LOs should be registered.

It would be easier to just register one LO and direct all covered loan applications through that one person.

"If we have not been offering consumer residential mortgage loans and are considering it at this time"

Really?? With all the training that you would have to do under the current rules and all the training that you should already be doing under the new TRID rules (as I am sure you do loans that fall under the new rules regardless of the fact that you may not currently do standard mortgages)?

Your bank really is thinking about opening a new line of business doing that few of a product??? The cost to get geared up will be astronomical compared to any hopeful income.

I agree with you completely rlcarey.

We do commercial real estate loans but for whatever reason the bank chose to stay away from consumer. I'm new to this position with this organization. I'm sure there are certain names (the not so pleasant ones) the LO's have for me since I'm insisting that they go through the TRID training just in case. Of course I'm also beating myself up by having to write procedures for it. I've suggested getting one LO registered, but because our offices are so far apart I'm not sure that it's a good solution.

Thanks for the advice. I certainly appreciate it.