Taking applications at one bank and closing at another

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  • #4978

    Originally posted in Compliance Masters Group Forum by cmitchell:

    We have a ‘sister bank’ in another state that did not have an active mortgage lending portfolio. Our bank is partnering with them in processing applications. Bank A has an employee, registered on their bank with the NMLSR, who takes applications and submits them to Bank B for processing, underwriting, closing, and selling on secondary market.

    How do we disclose this? On the 1003 application, the originator from bank A is listed as the Loan Originator, then Bank B is listed as the company name. Even though the originator doesn’t work for Bank B.

    Would this relationship be considered as a ‘mortgage-broker’ under Regulation Z? We are trying to determine if the fees would be included in the calculations for finance charge and/or points and fees.


    From your information, it seems Bank A is acting as a mortgage broker for loans that Bank B is closing/creditor.

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