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#1507714 - 02/09/11 09:30 PM
Re: How Many MLO's at Your Bank?
QCL
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Diamond Poster
Joined: Jun 2006
Posts: 1,194
South
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I, for one, would like to now where all the $$ is going?
No kidding!!! Somebody's making some bank off of us (pun intended).
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#1507748 - 02/09/11 09:48 PM
Re: How Many MLO's at Your Bank?
Sheldon Hendrix
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10K Club
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
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Definately seems to be a money grab...
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I don't repeat gossip, so listen closely...
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#1507751 - 02/09/11 09:53 PM
Re: How Many MLO's at Your Bank?
#Just Jay
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100 Club
Joined: Jan 2010
Posts: 192
Florida
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Especially since all fees are due up front and are non-refundable.
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"There should be a critical duration time after which it is perfectly acceptable to bite someone like a raptor." D. Shepherd
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#1507891 - 02/10/11 01:49 PM
Re: How Many MLO's at Your Bank?
Cats
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100 Club
Joined: Feb 2007
Posts: 127
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And ... we have to pay for all the training to get started.
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#1507945 - 02/10/11 03:10 PM
Re: How Many MLO's at Your Bank?
hrlady
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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And, no doubt many of us are registering employees as MLOs simply as an abundance of caution because they might or might not fall under the obfuscatory definition of MLO.
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Management is doing things right; leadership is doing the right things. Peter Drucker
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#1508061 - 02/10/11 04:45 PM
Re: How Many MLO's at Your Bank?
Truffle Royale
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100 Club
Joined: Jan 2010
Posts: 192
Florida
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Ours would not.
I've only registered the residential mortgage lender and the branch manager/consumer lender. While our senior lender does make loans, he's strictly commercial. If he did end up doing consumer residential loans because the first two people were unavailable, it's extremely unlikely that he'd do more than 5 in a 12-month period.
_________________________
"There should be a critical duration time after which it is perfectly acceptable to bite someone like a raptor." D. Shepherd
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#1508099 - 02/10/11 05:27 PM
Re: How Many MLO's at Your Bank?
renniks
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Platinum Poster
Joined: May 2010
Posts: 958
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That's what I am doing SF. We are a small bank and I have registered the President, COO, SLO and the Loan Processor. Any one of them might take an application or negotiate terms, even though 99% of the time it would probably be the SLO. Abundance of caution it is! As long as they did 5 or less a year, you wouldn't have to register.
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#1508142 - 02/10/11 06:08 PM
Re: How Many MLO's at Your Bank?
Bob The Banker
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10K Club
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
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We too are not taking the 'abundence of caution' route here... it's not an either or test, it's an 'and' test.
We are not taking the position that just because you touch a loan app, then you will be registered. We have stengthen procedures, reaffirmed expectations, encouraged 'whistleblowing' and are refining our business model in order to comply. But we are not going to register an additional 20-30 people in the bank just because of 'what if'.
_________________________
I don't repeat gossip, so listen closely...
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#1508306 - 02/10/11 08:25 PM
Re: How Many MLO's at Your Bank?
hrlady
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Platinum Poster
Joined: Sep 2007
Posts: 937
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Yes, its indeed hard to understand why an industry as heavily regulated as the banks that they need to "register" their employees and pay these kinds of fees. Just another burearacy. If the housing market continues to slow down any more, we'll only need to register one or so MLO's. The market was down 30% last year and this year is off as much or more. We moved one MLO to the CSR's desk already. Apps are just not there and rates are rising.
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#1508342 - 02/10/11 08:55 PM
Re: How Many MLO's at Your Bank?
renniks
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Gold Star
Joined: May 2005
Posts: 298
Maryland
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That's what I am doing SF. We are a small bank and I have registered the President, COO, SLO and the Loan Processor. Any one of them might take an application or negotiate terms, even though 99% of the time it would probably be the SLO. Abundance of caution it is! That's what we are doing also.
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#1508369 - 02/10/11 09:11 PM
Re: How Many MLO's at Your Bank?
Princess Romeo
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100 Club
Joined: Jan 2010
Posts: 192
Florida
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Very much so. I do try to point out that unlike the State registrants, our MLOs don't have to post 10 years worth of financials, have a credit report pulled, etc. but it doesn't help much. Neither does reassuring that not all of this will be available online to any random consumer.
_________________________
"There should be a critical duration time after which it is perfectly acceptable to bite someone like a raptor." D. Shepherd
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#1508370 - 02/10/11 09:11 PM
Re: How Many MLO's at Your Bank?
Sheldon Hendrix
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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We are taking the abundance of caution route, and our reasoning is Appendix A to the rule. While none of our loan assistants or processors really "negotiate" loan terms, they do provide disclosures. Since providing disclosures is negotiating loan terms under the appendix, and these personnel also accept applications, they would appear to be MLO's under the rule.
It's just plain stupid........... That's exactly my thinking.
_________________________
Management is doing things right; leadership is doing the right things. Peter Drucker
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#1508407 - 02/10/11 09:38 PM
Re: How Many MLO's at Your Bank?
Princess Romeo
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New Poster
Joined: Aug 2008
Posts: 5
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Oh yea! So much that I was told to "hold off a while and lets see what happens" on getting MLOs registered. Like it's going to change or go away before July?!?!?!?
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#1508496 - 02/10/11 11:27 PM
Re: How Many MLO's at Your Bank?
Truffle Royale
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10K Club
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
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It concerns me to see so many of peers seemingly throwing up their hands and saying, oh well, let us register them all. My president while he may discuss rate, he isn't going to be sitting down and completing a 1003.
I guess we saw this as a great opportunity to visit what we do and how. We looked at volume, locations, products, programs, expectations, procedures, bad habits, etc, and from that are determining who really needs to be doing loans, who is costing us money and causing us problems by doing loans, and who have picked up the slack from LO's who shouldn't be.
The costs, while annoying, are minimal especially from year to year renewal. But our LOs are well compensated... there is no reason that we are going to register a processor or assistant when the simple solution is to require the LO call and notify the borrower of what their rate will be like they should be. In the end, this simply more customercentric, and better relationship building.
We have looked at consumer lending, and based on need and volume right now, we do not need 3-4 people at each branch location able to do a loan (and often poorly), not when the volume simply isn't there. So what can we do? Register only one person in some cases, have one person cover 2-3 branches, tighten procedures, define roles, etc.
Those are the solutions we are looking for. We can always add people to the MLO ranks, but I just do not see the practicality of registering every person in the bank that has the ability to read a rate sheet or touch a piece of paper because we are scared.
Good controls, defined procedures and processes, and strong audit and review, IMO is a better solution that registering everyone because of 'what ifs'.
_________________________
I don't repeat gossip, so listen closely...
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