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#2277146 - 10/26/22 09:58 PM Limit of 3 loan originations
Compliance0411 Offline
Junior Member
Joined: Jun 2022
Posts: 26
I understand that there is a VA state law that limits you to three loan originations in Virginia, per rolling 12 month period, if you are not licensed. We purchase loans form a correspondent lender there and was wondering if that counted under the three limit. TO me it is not an origination it is a purchase and would not fall under the limit, but we are looking for some guidance.

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#2277148 - 10/26/22 10:12 PM Re: Limit of 3 loan originations Compliance0411
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 80,363
Galveston, TX
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2277508 - 11/02/22 07:22 PM Re: Limit of 3 loan originations Compliance0411
Compliance0411 Offline
Junior Member
Joined: Jun 2022
Posts: 26
Yes I have this information. I think I am relatively clear that we can not originate a loan, but we could purchase a loan from a correspondent lender and that would not be subject to the 3 loan limit nor require us to be licensed, or have a loan officer licensed in that state. My concern is when we underwrite a correspondent loan to issue a commitment to purchase a loan. Does that put us in danger of running afoul of the 3 loan limit?

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#2277510 - 11/02/22 07:45 PM Re: Limit of 3 loan originations Compliance0411
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 80,363
Galveston, TX
I assume you are not a depository institution. I do not believe underwriting pulls the trigger as long as you are not the creditor. If you are involved in negotiating loan modifications is a grey area.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2277516 - 11/02/22 09:08 PM Re: Limit of 3 loan originations Compliance0411
Compliance0411 Offline
Junior Member
Joined: Jun 2022
Posts: 26
Correct we are a non-depository lender and I agree 100%, negotiating terms is straying over the line to originating. Thank you for your guidance

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