If you look at the commentary to 1026.36(a), it describes managers and administrative staff and similar individuals who are employed by the creditor but do not receive compensation based on whether any particular loan is originated as not being loan originators.
We also have our tellers refer customers over to the personal bankers for equity loans and mortgage area for purchases. We don’t have paper applications and the tellers do not have access to the loan system to imput a lending application. One of the controls that we put in place with the SAFE Act was that (with the exception of audit staff) only persons with a NMLS number were to be given access to the loan system.
That was our interpretation of the loan originator rules – the tellers are not able to input or ‘take’ an application so they would not need to be registered. We didn’t want any employees outside of the ones registered to be helping customers with application questions. May not be ‘good customer service’ but hopefully it keeps us in compliance.