MLO, LO, or Neither? Developing a Compliance Management Program to Properly Identify and Oversee Staff for SAFE Act and Reg Z Rules Webinar Recording


* Please note that the recording links will be delivered to you via a downloadable word document in your confirmation e-mail.  The presentation that corresponds with the recording will be automatically delivered upon purchasing via email from the website.

Various regulatory requirements apply to employees at your organization, depending on if they are a Mortgage Loan Originator (MLO); a Loan Originator (LO); both; or neither.  Do you know what each employee is?  Do they?

Making a proper determination of what each employee actually does in their job is foundational to building a solid compliance management program.  In addition to SAFE Act requirements, Reg Z contains complex rules for employees involved in home lending including: qualification requirements, compensation restrictions, disallowed payments, and steering prohibitions.

Don’t be so quick to dismiss that teller who receives a referral fee for getting a home loan!  In so doing, did that teller just become a Loan Originator? Are you sure?  And if they did just become an LO, are they fulfilling the requirements demanded of them?

Now is the time to freshen your understanding of these requirements and clear out any cobwebs.  Develop a new program or rejuvenate your existing one to enjoy a robust, workable and meaningful oversight system.




Referral programs are hot, hot, hot!  Have you considered all angles of them to ensure they are compliant?

The SAFE Act has been around for a while now, and with time, full understanding and insights dwindle.  Staff members change and processes evolve.  Why are you doing what you do?  Take a new look at the requirements to make sure “what you’ve always done” is still appropriate and accurate.

Reg Z’s requirements at 1026.36 have always been complex, and the passage of time has not made them any clearer.  Examiners continue to look at this area of compliance with a fine-toothed comb, and your policy and procedures need to consider new lending programs, referral promotions, evolving employment roles, and broker relationships.  Don’t be caught off guard.

Don’t leave this matter solely in the hand of Human Resources, even if it is rooted in employment issues.  Does your HR department know the details of the SAFE Act and Reg Z?  Surely not.  That leaves you, the compliance professional, to develop and implement a rock-solid plan to comply.

This webinar recording will review SAFE Act and Reg Z requirements for MLOs and LOs, define and dissect key terms such as “Mortgage Loan Originator”, “Loan Originator” and “Compensation”, explore the impact of referral programs, and detail the requirements every LO must meet.   In addition to the webinar slides and manual, participants will receive a sample program to customize for their own institution, including a policy, employee survey, and sample training materials for in-house employee training.


Upon completion of this two-hour program recording you will understand:

  • Compare and contrast MLOs and LOs
  • Requirements MLOs must follow;
  • Requirements LOs must follow, including all 1026.36 provisions
  • How overly helpful employees can find themselves meeting the LO definition;
  • The Gotcha! game of referral and/or cross-selling programs;
  • Scenarios to illustrate real world examples;
  • Going beyond job titles;
  • Who owns MLO / LO oversight;
  • How to write (or update) an appropriate MLO / LO Program;
  • How to train all your employees, not just loan staff;
  • How to administer and track an employee survey;
  • Auditing the program
  • Sample Policy;
  • Sample Employee Survey;
  • Sample Training Materials.


The recording is designed for compliance officers, auditors, HR officers and lending managers.