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Reply To: LO Qualifixcations -Criminal Background Check

#4309
springhillbank
Participant

The statement to which I referred is taken from the following website:
https://www.federalregister.gov/articles/2013/02/15/2013-01503/loan-originator-compensation-requirements-under-the-truth-in-lending-act-regulation-z
Under Table of Contents
III.C.3
36(f) Loan Originator Qualification Regulations
Go to 36(f)(3)
Then 14th paragraph down

(This is a large website; this is found almost 2/3’s of the way down)

NOTE:
When I went back on this website, I realized that what I copied was in Section III Summary of the Rulemaking Process

At the top of this page on the website is Section I Summary of the Final Rule

Under the Final Rule scroll down to Loan Originator Qualification and Identifier Requirements. This is what is said

“Loan Originator Qualifications and Identifier Requirements. The Dodd-Frank Act imposes a duty on individual loan officers, mortgage brokers, and creditors to be “qualified” and, when applicable, registered or licensed to the extent required under State and Federal law. The final rule imposes duties on loan originator organizations to make sure that their individual loan originators are licensed or registered as applicable under the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE Act) and other applicable law. For loan originator employers whose employees are not required to be licensed, including depository institutions and bona fide nonprofits, the rule requires them to: (1) Ensure that their loan originator employees meet character, fitness, and criminal background standards similar to existing SAFE Act licensing standards; and (2) provide training to their loan originator employees that is appropriate and consistent with those loan originators’ origination activities. The final rule contains special provisions with respect to criminal background checks and the circumstances in which a criminal conviction is disqualifying, and with respect to situations in which a credit check on a loan originator is required”

This final rule states that the unregistered Loan Originators meet criminal background standards similar to existing SAFE Act – so, fingerprinting or not??????