Goof-proof MLO / LO survey to identify and manage employees
09/13/2020
How can my bank make sure we correctly classify our employees as a Mortgage Loan Originator or a Loan Originator? It is confusing
Rebekah F Leonard, CRCM is the owner and founder of Elucidate, LLC, a compliance consulting and training company based in Bozeman, Montana. Rebekah has been in the finance and banking industry since 1995, with experience including customer service, teller, bank operations, loan review, loan officer, branch manager, BSA, security officer, and compliance. In 2001 she became her bank’s compliance officer, rising in 2015 to the level of Senior Vice President of Compliance and CRA, helping the bank grow from $300MM in assets to over $1B at its acquisition. She has successfully navigated through five FDIC Compliance Exams, and before starting her company, worked specifically and deeply in lending compliance as a specialist in the field. Rebekah has a bachelor’s degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and is a Certified Regulatory Compliance Manager since 2006.
09/13/2020
How can my bank make sure we correctly classify our employees as a Mortgage Loan Originator or a Loan Originator? It is confusing
09/06/2020
Is my bank exempt from the anti-steering requirements (i.e. giving the applicant 3 other loan options) in the LO Comp rules of 1026.36?
08/30/2020
Our Executive VP earns a substantial annual bonus. He doesn’t really do any real estate lending, but he certainly talks with many bank customers (often on the golf course) about how the bank can provide various loan solutions, including home loans. Up to this point, he has kept his NMLS ID # and registration current “to CYA”. I’m concerned his bonus may be non-compliant with Loan Originator Compensation requirements. Should I be worried?
08/23/2020
Who should manage the NMLS registration for our Mortgage Loan Originators (MLOs)? Is that an HR function, or should compliance do it?
08/19/2020
We have started a new referral program to pay bank employees a modest fee to send possible borrowers to our real estate department. Can we do this?
08/16/2020
Must our Loan Originators (LO) be registered on the NMLS Registry?
08/02/2020
My bank is a small creditor who makes HPMLs. We’ve been claiming the escrow exemption, but now I’m not so sure we should. Sometimes we set up accommodation escrows for extenuating circumstances – does that cause problems?
07/26/2020
Our community bank is opening a new branch in a bigger city. Will we lose our “rural and underserved lender” status?
07/12/2020
My bank makes QM Balloon loans and one of my new loan officers is insisting he does not have to stay under the QM 43% Debt to Income cap. He does, doesn’t he?
07/05/2020
To be a Small Creditor QM, must the loan be made in a rural or under served area?