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Ask the Compliance Experts: June 2017

QUESTION: A discussion has arisen in our office regarding the ability to recapture an EPO or EPD fee from a loan officer’s commission.  Is this allowed under Regulation Z/Loan Officer compensation regulations? ANSWER: Whether a charge for an EPO or EPD can be deducted from an LO’s compensation is dependent …

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Ask the Experts: February 2017

I have a question regarding loan originator advertising/marketing. I am curious as to what, if any, restrictions there are to loan originator self- promotion. I am familiar with MAP rules, Regulation Z, that I must include NMLS ID, and all of the general guidelines as to what advertisements must or …

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Ask the Compliance Experts: January 2017

Q: I am looking for direct, plain, and straight-forward language to help answer questions for my manager. If an employee asks a customer “Have you heard about our mortgage rates? Let me have so-in-so call you,” and this later results in the LO ‘so-in-so’ closing a loan, can we pay …

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Ask the Compliance Experts: December 2016

Question: Should we have the borrower sign an authorization prior to pulling their credit report? Or is a written note in the LOS system stating the borrower authorized us to pull their credit sufficient? Thank you in advance. Answer: Written authorization is required before a lender or broker is permitted …

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Ask the Compliance Experts: November 2016

Question: To whom it may concern: can you provide me with the regulation summary for co-marketing with other real estate professionals, as well as referral sources? Thank you. Answer: We assume that you are not referring to any type of Marketing Services Agreement and request our opinion relating to joint …

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Ask the Compliance Experts: August 2016

A: I enjoy your magazine.  It’s one of the best in the industry.  Please find an ECOA/FCRA question below: When we take adverse action on a joint application because one of the applicants has a credit score that is below our minimum, how do we complete the co-applicant’s ECOA/FCRA denial …

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Ask the Compliance Experts

Q: I read your articles in the Mortgage Compliance Magazine, and I am wondering if you can answer a Reg B question for me. I’ve done research and exhausted my sources and still cannot find a definitive answer to this ECOA [Equal Credit Opportunity Act] query: After we have a …

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