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#1507683 - 02/09/11 09:06 PM How Many MLO's at Your Bank?
Sheldon Hendrix Offline
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I thought it would be fun to see the diversity of registration burdens for bankers utilizing this forum. Answer based on how many approximate MLO's you believe you have under the rule.
How Many MLO's at Your Bank?
single choice


Votes accepted starting: 02/09/11 09:02 PM
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#1507699 - 02/09/11 09:20 PM Re: How Many MLO's at Your Bank? Sheldon Hendrix
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I, for one, would like to now where all the $$ is going?

$100 per bank, per year
$110 admin's multi factor fee ($55 per Admin)
$99 per MLO - if they use electronic fingerprint filing

And this is just the cost for the first year!

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#1507714 - 02/09/11 09:30 PM Re: How Many MLO's at Your Bank? QCL
Sheldon Hendrix Offline
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Originally Posted By: QCL MamaBEAR
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
#Just Jay Offline
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Definately seems to be a money grab...
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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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Especially since all fees are due up front and are non-refundable.
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#1507891 - 02/10/11 01:49 PM Re: How Many MLO's at Your Bank? Cats
hrlady Offline
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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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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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#1508004 - 02/10/11 03:52 PM Re: How Many MLO's at Your Bank? Sinatra Fan
renniks Offline
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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!

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#1508033 - 02/10/11 04:15 PM Re: How Many MLO's at Your Bank? renniks
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But it's not just taking an application OR negotiating terms. It has to be taking an application AND negotiating terms. A person has to meet both prongs of the test in order to be an MLO and have to register. Would your Loan Processor ever do that, renniks?

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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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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.
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#1508099 - 02/10/11 05:27 PM Re: How Many MLO's at Your Bank? renniks
Bob The Banker Offline
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Originally Posted By: renniks
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
#Just Jay Offline
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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'.
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#1508245 - 02/10/11 07:45 PM Re: How Many MLO's at Your Bank? Truffle Royale
renniks Offline
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Yes TR, We are a very small bank. In the absence of the President and SLO she would do both.

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#1508306 - 02/10/11 08:25 PM Re: How Many MLO's at Your Bank? hrlady
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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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#1508318 - 02/10/11 08:33 PM Re: How Many MLO's at Your Bank? ccman
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That's unusual but definitely understandable given your size, rennicks. My comment was more to what Sinatra said about over abundance of caution. As long as it's recognized that the person has to do both items to meet the test of being an MLO, then ythey should register.

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#1508327 - 02/10/11 08:43 PM Re: How Many MLO's at Your Bank? Truffle Royale
Sheldon Hendrix Offline
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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...........
Last edited by Compliance Rules; 02/10/11 08:44 PM.
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#1508342 - 02/10/11 08:55 PM Re: How Many MLO's at Your Bank? renniks
RobinB Offline
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Originally Posted By: renniks
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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#1508362 - 02/10/11 09:07 PM Re: How Many MLO's at Your Bank? RobinB
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Where the heart is
Anyone getting push back from employees over the intrusive personal nature of the registration?
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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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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.
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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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Originally Posted By: Compliance Rules
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.
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#1508407 - 02/10/11 09:38 PM Re: How Many MLO's at Your Bank? Princess Romeo
carols Offline
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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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#1508475 - 02/10/11 10:42 PM Re: How Many MLO's at Your Bank? carols
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Has anyone asked a regulator about the appendix? I'm holding off till my exam early this summer and will ask all my questions then. Based on the reply I get, I'll still have time to register if they determine I must. But I'm hoping the argument I've put together will persuade the Feds that I'm ok the way I am.

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#1508496 - 02/10/11 11:27 PM Re: How Many MLO's at Your Bank? Truffle Royale
#Just Jay Offline
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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'.
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#1508498 - 02/10/11 11:31 PM Re: How Many MLO's at Your Bank? #Just Jay
Kathleen O. Blanchard Offline

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I agree that this can be an opportunity to streamline processes and make them better!
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#1508518 - 02/11/11 01:40 AM Re: How Many MLO's at Your Bank? Kathleen O. Blanchard
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Well said, Just Jay.

I'm hoping there are more banks out there that are thinking this through before they whip out the checkbook and for no real reason put their people through this scrutiny unnecessarily. As Kathleen said, it's a golden opportunity to revisit who does what and why and put the onus back on the LOs where it rightfully belongs. Personally, I'd love to be able to say 'Sorry, I can't do that. I'm not registered.'

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