We do not offer mortgage lending only construction loans. Must our loan officers register under the SAFE Act requirements?
I recently attended a Harland Laser Pro Regional Conference. It was indicated that the SAFE ACT states that mortgage lenders must register for a NMLSR. Does this include loan officers that just take Home Equity Loan and HELOC applications?
Could you please settle a disagreement we’re having regarding MLOs as defined by the S.A.F.E. Act? All of our mortgage (as defined by the S.A.F.E. Act) underwriters receive only straight salary compensation. They receive no additional compensation, e.g. incentive pay, bonuses, commissions, based on the number of mortgages they underwrite or the rates and terms of those mortgages and they do not engage in any solicitation of mortgage loan business. All rates and terms are set by senior management. There are no rate spreads and all underwriters are bound by the set rates and terms. They engage in no negotiating of rates or terms with applicants. Although manufactured home underwriters are permitted to consider a written request from an applicant for a deviation from the posted terms, the granting of the requested term does not affect the underwriter’s compensation. Do you believe these underwriters would be considered MLOs as defined by the Act.
A local attorney has informed one of our bank officers that the SAFE Act would require a lender to be a registered mortgage loan originator in order to close loans for lot purchases (land only). I haven't heard that in any of the seminars I have attended. Is this true?
We are a State Bank. Do our loan officers and assistants need to be registered in Texas? I'm getting conflicting information from different sources.
Under the provisions of the Safe Act, do bank loan officers have to be trained and tested, or only fingerprinted and have a background check? I have heard it both ways.