Is the action of pulling credit reports as an individual Loan Originator considered a licensed or unlicensed activity?

I have searched for definitions of what is considered licensed/unlicensed activity in LO Comp. as part of Reg Z but have been unsuccessful. If anybody can provide this definition or a point of reference, that would be greatly appreciated!

Thanks

You mean you have a secretary pull a credit report and that is it - they then hand it off? No other interaction with the customer and is not involved in underwriting, etc.

I'm looking for a hypothetical answer either way, whether it was an individual LO or their secretary - and simply the action of pulling the report, with underwriting held completely separate.

This determination is very fact specific. they would be a loan originator if they do the following: takes an application, offers, arranges, assists a consumer in obtaining or applying to obtain, negotiates, or otherwise obtains or makes an extension of consumer credit for another person; or through advertising or other means of communication represents to the public that such person can or will perform any of these activities.

If they are not doing any of those, then they are not in relationship to that specific transaction.

Assuming they fit that description based on their activities. I'm trying to determine whether their pulling of credit reports is considered a licensed activity or unlicensed.

I am confused - what does pulling a credit report have to do with anything? That is a clerical function. Whether they are a loan originator on a specific transaction is based on the definition provided above.

I'm trying to determine whether their pulling of credit reports is considered a licensed activity or unlicensed.

Maybe you should explain what you mean by "licensed or unlicensed" activity. I have never heard any requirement for a person to be licensed to be able to pull a credit report.

The simple act of pulling a credit report does not make one a loan originator unless one is also performing the duties outlined by Randy.

BTW, welcome to BOL.