Okay - this is a first for me. In regards to the SAFE Act, for branch employees that take loan applications are they required to be registered? My feeling is no, but the Act defines a Mortgage Loan Originator as someone who takes a residential mortgage loan app (loan primarily for personal, family, or household use that is secured by a residence) and offers or negotiates terms of the loan for compensation or gain. We do have a separate Mortgage Dept and those originators will be registered. Any feedback is appreciated - thanks!

Do they discuss terms? If not, chances are they will not meet the full definition.

Yes, they will discuss options with the customer, take the application and submit to the lending area for decision.

Then they likely will be an MLO if you continue with that process. If you will do a search on this forum and Financial Reform possibly for SAFE Act, you will find good discussions to study.

Thanks - I guess they'll all have to be registered. I was trying to find a way around it, but I guess not.