What does it mean when you look up a bank and the status is "inactive"? Does that mean that the bank had to renew their registration during the annual renewal period?

I believe that's correct, I recall reading that individuals who are registered and their renewal isn't paid will be listed as inactive, so it would make sense for the same to apply to a financial.

In fact...

"Annual Renewal/Reactivation
Q. How long does a registration remain active?
A. Federal regulations require individual mortgage loan originator registrations and institution accounts be renewed on an annual basis in order to remain active. Registrations that are not renewed will become inactive."

So, if a Bank has let their registration go inactive, does that mean that any loans originated up until they re-actived it are out of compliance?

I'd say that would be a serious issue, yes. I don't believe they would be qualified to lend during this period. I can't find any specific guidance at a quick glance as to what may happen to loans originated during an inactive period though.

I know that about 4 or 5 weeks ago I got an e-mail to renew and pay an additional $55.00. Maybe you didn't receive that e-mail or pay the fee.

I think the annual $55 fee is for your administrators who have to have a security creditial.

I believe the institution has to renew before any of its loan officers can renew. I think the cost is only like $100 or so.

If your bank registered initially then realized the loan officers are under the di minimus exception (and continue to be) and they didn't register, there should be no reason to renew the bank's registration should there?

I wouldn't think so. But you have to monitor loans very closely to make sure your lenders don't go over the limit for the de minimus exception. If you don't have very many lenders or don't do very many RE loans that it wouldn't be a big deal, but for our institution, it would be a nightmare to track.

Ok, thanks. Yes, it is hassle to monitor.