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#2016113 - 05/26/15 10:05 PM Job Descriptions
Tesla Offline
Power Poster
Joined: Nov 2003
Posts: 3,726
I am reviewing the job description of a non-MLO that includes the wording "Cross sells other products of the bank". Since another product of the bank is mortgage secured consumer loan, can that get us in trouble? The person can say we offer mortgage loans and then is required to transfer them to a MLO for further discussion.

Thoughts on how to re-word this or if I should?
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S.A.F.E. Act Forum
#2016169 - 05/27/15 02:19 PM Re: Job Descriptions Tesla
TMatt87 Offline
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TMatt87
Joined: May 2011
Posts: 1,987
Idaho
I think it's fine the way it is. You just need to train the non-MLO on what they can and can't do.
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#2016171 - 05/27/15 02:21 PM Re: Job Descriptions Tesla
Tesla Offline
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Joined: Nov 2003
Posts: 3,726
Great! Thank you for your thoughts! smile
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#2016283 - 05/27/15 05:43 PM Re: Job Descriptions Tesla
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
They would not be an MLO for the SAFE Act requiring registration.

BUT, keep in mind though, that if the employee is initiating the cross-sale of a closed-end consumer loan, they are "offering" under the Reg Z compensation rules, and would be classified as a Loan Originator subject to the compensation restrictions of 1026.36.
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#2016395 - 05/27/15 08:25 PM Re: Job Descriptions Tesla
Tesla Offline
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Joined: Nov 2003
Posts: 3,726
Thanks for the reminder, Dani! smile
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