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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?
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