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?

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.

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.

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?

See my response..........

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.