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#1875498 - 12/03/13 04:11 PM Approval Authority
notuntermywatch Offline
Gold Star
Joined: Jun 2006
Posts: 392
MN
Our Chief Credit Officer has the abilitly per loan policy to approve exceptions to consumer loans, which effectively means they can approve consumer loans. The only time he touches consumer loans is when there is an exception a banker needs approval on.

So given this, would I have to consider him a loan originator per Regulation Z?

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#1875510 - 12/03/13 04:36 PM Re: Approval Authority notuntermywatch
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,470
Midwest
We registered our Chief Credit Officer as a MLO for this kind of situation. Also, they are responsibile for employee/officer loans even though another MLO does majority of the work.

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#1875526 - 12/03/13 05:09 PM Re: Approval Authority notuntermywatch
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,898
Galveston, TX
Underwriters do not need to be "registered" under the SAFE Act nor do they qualify as a "loan originator" under Regulation Z, if that is all that they are doing.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1875557 - 12/03/13 06:16 PM Re: Approval Authority rlcarey
gunches Offline
100 Club
Joined: Dec 2005
Posts: 210
This question came up for us this morning as well. In our bank, a MLO does the interview process, application, underwriting, processing. If it is over the MLO's lending limit, it is sent to a senior lender for approval. That is all he does. Does the senior lender need an MLO just to put his stamp of approval on the loan?

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#1875561 - 12/03/13 06:19 PM Re: Approval Authority notuntermywatch
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,898
Galveston, TX
See my response..........
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1875570 - 12/03/13 06:38 PM Re: Approval Authority notuntermywatch
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,470
Midwest
The only reason we registered our senior lender as an MLO is because the loan is booked under his responsibility code. We only have 6 staff registered so it wasn't a huge deal to get him registered plus he is there for a backup in case one of the other MLOs is out.

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