Site visits – “Mock Audits”

Compliance Services intends to add this service on a limited basis.

If you have interest in our coming to your facility and “auditing” your entity to see how you would do when the state or the feds come calling, send me an email at nl@lockelaw.us.

These visits clearly show us what Brokers and Lenders thought they knew but didn’t.

These visits can save thousands in potential fines.

Nelson A. Locke, Esq.

(800) 656-4584

H.R. 2121 – Hiring Bank Originators

Hello all, Happy Friday.

Back in April 2015 – HR 2121 was introduced in the House of Representatives, and the author asked for fast track. Well, it has made its way to the Senate but is stil in committee.

For those of you who were unaware, this bill would have authorized a conditional 90 day license to allow Brokers and non-bank Lenders to hire bank originators on a 90 day “honeymoon” during which the originator had to apply for an obtain a standard non-bank approval from the NMLS and their state regulator.

This was a good plan for a situation previously not considered by the CFPB or the Safe Act.

Because several of you seem to think this is in force, I wanted to advise you, it is NOT. While it passed in the House, it never passed in the Senate, thus it has died.

So don’t hire any bank originators unless they have already started the licensing process, and understand they cannot originate for you until the license is issued.

Respectfully,

 

Nelson A. Locke, Esq.

(800) 656-4584