Answer:
Yes. The SAFE Act and regulations include definitions of terms. The key definition in this case is that of "residential mortgage loan." That term "means any loan primarily for personal, family, or household use that is secured by a mortgage, deed of trust, or other equivalent consensual security interest on a dwelling (as defined in section 103(v) of the Truth in Lending Act, 15 U.S.C. 1602(v)) or residential real estate upon which is constructed or intended to be constructed a dwelling, and includes refinancings, reverse mortgages, home equity lines of credit and other first and additional lien loans that meet the qualifications listed in this definition." [12 CFR Part 208, Section 208.102].So, if you have employees who meet the definition of "mortgage loan originator" (also defined in Section 208.102) in their handling of HELOC or other residential mortgage loans, they need to be registered.
And don't forget! The initial registration period for mortgage loan originators employed by federally-supervised financial institutions is right around the corner! July 29, 2011.
First published on BankersOnline.com 7/18/11
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