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1. May a loan processor email (subject to E-Sign of course) preliminary disclosures to the consumer without qualifying as a loan originator, IF we include a cover letter signed by the MLO/Loan Originator?
2. Does communicating a denied decision qualify one as a Loan Originator?
3. In terms of the credit report requirement: I don’t see any age or refresh recommendations; what are your thoughts? Can we satisfy the requirement with a 3 or 4 year old credit report for existing MLO or LO that were hired prior to any regulatory background standards went into effect?
4. Obtaining information requirement on administrative, civil, or criminal activity by government jurisdiction – the requirement allows when not an MLO such information “may be obtained from the individual loan originator” – (LOL!) Should we go so far as to have the Loan Originator sign a statement of fact to document their file?
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