[aslauter]

In reading the new TILA Loan Originator rules, seems we may be faced with registering additional folks as MLO’s that weren’t covered under the SAFE Act – for example – I have FSR’s that take Home Equity Loan applications. They don’t offer or negotiate terms – we made sure of that so that we didn’t have to register them last year under the SAFE Act – but now it looks like we may have to register them anyway because of the more generous definition under TILA. Is everyone else reading it this way?

[jholzknecht]

I agree. The revised definition of “mortgage loan originator” in the proposed rule does expend the community of those who must register.

[aslauter]

Ughhh! o.k. so this is the answer I was expecting but NOT the one I wanted. 😉

[Author]

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