Our mortgage department is wanting to provide a packet of information to our customer service representatives/tellers that assists them in directing customers to our mortgage department. The packet consists of a worksheet or checklist of things needed to apply for a mortgage loan, such as W-2's, pay stubs, bank statements, etc..., and a mortgage application. It also will contain a business card of one MLO in our mortgage department that will follow up with these requests. This packet of information will be provided to the customer.
The employee will also have a sheet to take the customer's constact information to forward to the mortgage department. There is no referral fee being given to the teller or CSR.
Does the act of providing the mortgage application and/or referring the customer to an MLO make the teller/CSR a loan originator per Regulation Z? What if no application were provided, just the checklist of needed items and a business card for the MLO? Also, what if we included the mortgage application, but simply referred them to our mortgage department?