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#2147711 - 09/27/17 12:31 PM MLO Matching Borrowers to Sellers
Midwest Banker Too Offline
Member
Joined: Jul 2008
Posts: 51
Midwest
Our originators want to bring buyers and sellers together. By that I mean originators can keep track of which of their customers are selling their old home while looking to purchase a new and then match them up to other customers doing the same thing (or could be an existing renter that’s looking to purchase a home).

But with that, do we have any regulatory conflict of interest, or would we be acting in a realtor capacity and not having a license? Or is this a practice that we could in fact do?

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#2147714 - 09/27/17 12:38 PM Re: MLO Matching Borrowers to Sellers Midwest Banker Too
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
State law issue - sounds like they are acting as a realtor. You also need to check with your regulator regarding allowable banking activities. Also, ask your legal counsel regarding any risks and liabilities this could present.
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#2147717 - 09/27/17 12:41 PM Re: MLO Matching Borrowers to Sellers Midwest Banker Too
Midwest Banker Too Offline
Member
Joined: Jul 2008
Posts: 51
Midwest
This is very helpful. Thank you.

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#2147769 - 09/27/17 02:54 PM Re: MLO Matching Borrowers to Sellers Midwest Banker Too
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
keep track of which of their customers

I'd be concerned about potential privacy issues also.
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The opinions expressed are mine and they are not to be taken as legal advice.

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