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#1923797 - 05/16/14 02:35 PM Re: MLO TRAINING Complianceking
Matt_B Offline
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Matt_B
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A CU, Where Regs Don't Apply
Here's the course description for you.

Quote:
The new rules issued by the CFPB pursuant to Dodd-Frank amended Regulation Z now require that a loan originator must receive periodic training. This training must cover federal and state law requirements that relate to the individual loan originator's origination activities. The training is not specific about how much or what type of training is enough, but the rule provides a safe harbor. The rule indicates that one way to obtain a safe harbor is for the MLO to receive training approved by the NMLS for continuing education.

You can obtain the safe harbor through CUNA's NMLS-approved comprehensive mortgage loan originator course. Click here to register and learn more.


It's overkill for what's needed, probably, but given our current absence of regulation training for our lenders, I was more than willing to push that this needed to be done by the department heads, then make them work with me to disseminate it down the chain to everyone else.
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Loan Originator Compensation Rule
#1923850 - 05/16/14 03:30 PM Re: MLO TRAINING Complianceking
rlcarey Online
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Galveston, TX
You forgot an important piece:

"to the extent that the training covers the types of loans the individual loan originator originates and applicable Federal and State laws and regulations."

If the training was as lacking as you seem to have thought it was, then there is no safe harbor.
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#1923872 - 05/16/14 03:47 PM Re: MLO TRAINING Complianceking
Matt_B Offline
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Matt_B
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Agreed, as I read 1026.36(f)(3)(iii) to try to figure out exactly what they are claiming they are accomplishing for us. If it's being touted as approved by the NMLSR, I guess you still can't trust that it's sufficient. And it's not that it was lacking in state-specific content, or loan-product specific content, but general regulations that apply to most FIs across the country that I thought were lacking. I'm waiting for the satisfaction survey to come to me so I can share my thoughts, for whatever that will be worth. smirk
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#1924631 - 05/20/14 01:44 PM Re: MLO TRAINING Complianceking
hgliii Offline
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Matt,
NMLS only approves the Licensing classes. I have never seen a NMLS class approval for registered MLOs. I consulted with a CU to bring their P&P current with CFPB for last 12 months. I did not find any NMLSR training material issued from NMLS.
We modified the NMLS Licensing/CE courses and modified the training to that specific CU.

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#1924650 - 05/20/14 02:13 PM Re: MLO TRAINING Complianceking
Matt_B Offline
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Matt_B
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The understanding I have is that if you are using a course certified to cover the licensed MLOs, then your registered MLOs should have safe harbor for their training. Again though, that requires that the training actually be relevant to their jobs, and cover all things they need. It was the initial roll-out of the program, and as the only compliance person in attendance, I provided quite a bit more feedback than they were looking for, I'm sure smirk I was tasked by the trade association to do so though, so hopefully they actually take the response to heart going forward.
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#1924920 - 05/20/14 07:16 PM Re: MLO TRAINING Complianceking
hgliii Offline
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Go to Hondros Learning and look at its material. We use it in TN, it is NMLS Certified, for our 20 hour comprehensive and 8 hour CE classes. They may have material for registered MLOs training. I have not looked for the registered specifically, but they may have anticipated it.

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#1925385 - 05/21/14 08:56 PM Re: MLO TRAINING Complianceking
ComplianceRegs Offline
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My question is how do you determine which state laws to cover in the training when the bank operates in one state, but can make mortgage loans in any state?
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#1925648 - 05/22/14 03:48 PM Re: MLO TRAINING ComplianceRegs
ComplianceRegs Offline
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Originally Posted By: ComplianceRegs
My question is how do you determine which state laws to cover in the training when the bank operates in one state, but can make mortgage loans in any state?


Any thoughts? I am specifically concerned with how you determine which states to cover in the training.

(iii) Provide periodic training covering Federal and State law requirements that apply to the individual loan originator's loan origination activities.
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