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#2092858 - 08/11/16 09:46 PM Mortgage Loan Originator
AllTheRules Offline
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Joined: Jan 2013
Posts: 13
I have reviewed the SAFE Act and have not been able to determine an answer to the following question. Can a Mortgage Loan Originator maintain a State License and NMLS# to originate loans for a broker company and also obtain a separate Federal Registration with a different NMLS# to originate loans for a bank, as a part-time employee? The bank is in a separate market than the broker company?

A verbal conversation with NMLS indicated that a bank can register someone under their Federal number while they maintain a license under the State number. They advised seeking additional guidance on whether the Mortgage Loan Originator can originate loans for each company.

If you can provide any guidance on how this would be viewed in Texas as allowable or not, it would be greatly appreciated.

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#2095594 - 08/26/16 06:58 PM Re: Mortgage Loan Originator [Re: AllTheRules]
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
I would suggest contacting your state department of financial institutions and your federal regulator. It looks like a conflict of interest to me. The NMLS license/registration is the last thing to worry about. You need to resolve whether or not this person can be both a broker and a bank MLO, even if in different markets.
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.

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#2095597 - 08/26/16 07:04 PM Re: Mortgage Loan Originator [Re: AllTheRules]
rlcarey Online
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Joined: Jul 2001
Posts: 70,844
Galveston, TX
I had suggested early that they contact the Texas Department of Savings and Mortgage Lending and ask them. Outside of this representing a huge conflict of interest regardless of the fact the broker is "out of market".
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