August 26, 2013 at 3:50 pm EDT
#3877
rcooper
Member
You are correct. And reason would indicate that you wouldn’t have to do a background check if one had already been done at the time of hire. However, the regulation or commentary doesn’t seem to give an exception for this. Take a look at page 367 and 368 of the final rule: https://files.consumerfinance.gov/f/201301_cfpb_final-rule_loan-originator-compensation-preamble.pdf