[rcooper]

A question we received:

Is Reg Z training required or just recommended?

[rcooper]

There is not a blanket training requirement in Regulation Z like you might see in some laws/regulations. However, there are loan originator training requirements. This requirement is a requirement for LOs in 1026.36(f). In addition, you should consider risk (products, changes to the reg, recent audit findings) to help determine how frequently your lending staff (LOs and others) will need training on Regulation Z. Regulation Z the is largest regulation on the lending side and has significant changes over the last few years, I would recommend that you provide training at least annually and more frequently if you’ve had Reg Z related audit findings, new products, changes to the reg, etc.

1026.36(f)(3) For each of its individual loan originator employees who is not required to be licensed and is not licensed as a loan originator pursuant to § 1008.103 of this chapter or State SAFE Act implementing law:
… (iii) Provide periodic training covering Federal and State law requirements that apply to the individual loan originator’s loan origination activities.

Commentary 36(f)(3)(iii)
1. Training. The periodic training required in § 1026.36(f)(3)(iii) must be sufficient in frequency, timing, duration, and content to ensure that the individual loan originator has the knowledge of State and Federal legal requirements that apply to the individual loan originator’s loan origination activities. The training must take into consideration the particular responsibilities of the individual loan originator and the nature and complexity of the mortgage loans with which the individual loan originator works. An individual loan originator is not required to receive training on requirements and standards that apply to types of mortgage loans that the individual loan originator does not originate, or on subjects in which the individual loan originator already has the necessary knowledge and skill. Training may be delivered by the loan originator organization or any other person and may utilize workstation, internet, teleconferencing, or other interactive technologies and delivery methods. Training that a government agency or housing finance agency has established for an individual to originate mortgage loans under a program sponsored or regulated by a Federal, State, or other government agency or housing finance agency satisfies the requirement in § 1026.36(f)(3)(iii), to the extent that the training covers the types of loans the individual loan originator originates and applicable Federal and State laws and regulations. Training that the NMLSR has approved to meet the licensed loan originator continuing education requirement at § 1008.107(a)(2) of this chapter satisfies the requirement of § 1026.36(f)(3)(iii), to the extent that the training covers the types of loans the individual loan originator originates and applicable Federal and State laws and regulations. The training requirements under § 1026.36(f)(3)(iii) apply to individual loan originators regardless of when they were hired.

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