I have been going back and forth with these questions for a while. Consulted with our outside auditors but am still second guessing - please help.
My institution has not made any consumer loans since Oct 2009. However we continue to use the 1003 Application for loans on residential property (investors buying rental homes), these loans are 100% business purpose loans. Do I need to register our loan officers?
Also, we do occasionally modify/renew existing consumer loans, would that create a need to register the loan officers?
Finally, does the institution need to be registered regardless of whether you register the loan officers?
Thank you for any help.