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Do our LOs that were employed prior to Jan 1, 2014 that were properly registered as MLOs have to complete the initial 20 hours of training required by new LOs in 2014? Or just the 8 hours of ongoing training?
If you comply with the SAFE Act rules for federally regulated institutions (Part 1007, Reg G) there are not training requirements for your MLOs and, therefore, your all of your LOs must comply with the training requirements in Reg Z, 1026.36.
If your MLOs comply with the state licensing SAFE Act rules (Part 1008, Reg H) your MLOs will have already completed required training and, therefore, Reg Z 1026.36 does not require training for these MLO-LOs.
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