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It is my understanding that employees who are paid referral fees for referring potential customers to our mortgage department would qualify as “loan originators” under Reg Z. Because they just give general information, they would not qualify as a MLO, requiring NMLS registration. I also believe as LOs, we only have to do crimnal background checks,obtain a credit report, and do some Reg Z training about this. At this point the referral fees would not have to be included in the points and fees calculation. Is this correct?
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