Brokers – license yourself in Texas!

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TEXAS is a broker friendly state.

The regulators here are reasonable and fair.

If you are thinking about expanding your business, and maybe dropping some broker un-friendly states like (you know who you are), you can license yourself fairly quickly.

Compliance Services is now offering a registered agent and office space option to our clients.

Using us you can keep your startup costs low while building your Texas contacts and marketing. 

If you are interested in expanding into the great state of TEXAS, contact us today.  While we serve brokers and lenders nationwide, we are located in the Dallas Metroplex. 

Special invitation to our Florida and California clients. Come on down!

Respectfully,

Nelson A. Locke, Esq

(800) 656-4584

http://www.lockelaw.us

 

 

The LIBOR is being phased out.

Please be aware of this. Your lenders will be migrating loan programs away from the LIBOR and over to other, more “stable” indexes during 2020.

Some states, such as New York, have already asked for brokers and lenders to submit a plan to manage the transition. I have a template we can use if you receive such a request.

For most of you, the transition will be effortless as you do not keep the paper, thus no servicing issues regarding the LIBOR.

If you have any questions, here is a great link for information.

https://www.schwab.com/resource-center/insights/content/libor-phase-out-what-does-it-mean-you

That’s it for now.

Nelson A. Locke, Esq

(800) 656-4584

http://www.lockelaw.us

 

 

 

 

Have you received a Complaint from “Legal Justice Advocates” regarding allegations of disparate treatment of the visually impaired?

thIf so, please email me at once. While we believe this to be questionable,  you need to protect yourself and our Florida Team is ready to assist.

This link can help you to understand what is going on.

https://www.actionnewsjax.com/news/local/attorneys-in-trouble-over-ada-lawsuits-against-local-small-businesses/754005293/   

Forward what you recieved to nl@lockelaw.us and in the subject line put ADA ISSUE.

Thanks.

Nelson A. Locke, Esq.

(800) 656-4584

 

Clarification on Temporary Authority Post……..

confusedThis Temporary Authority (120 days) relates to Mortgage Loan Originators transitioning from federally insured institutions (“NMLSR”) to non-bank lenders (“NMLS”), as well as already licensed individuals holding valid personal and/or broker or lender licenses that are moving or expanding their mortgage licensing to other states.

Any questions? Give us a shout.

Nelson A. Locke, Esq.

(800) 656-4584

Important News about Temporary Authority to act as an MLO…..

Thanks to Max Lewis for providing this information.

“A little less than 2 weeks ago a new process went into effect in NMLS. It is called the “Temporary Authority to Operate.” You may or may not have heard of this. Basically, it allows a loan officer to be able to start originating loans the day their loan officer license application is submitted to the state.
Please note though that there are several conditions which must be met first:
• The company must already have a license to operate in the state in which you wish to license this loan officer.
The loan officer must be a W-2 employee.
• The loan officer must have at least one year of experience with a bank (deposit taking) preceding the date of application submission or 30 days of experience (licensure) at a non-bank company preceding the date of application submission – this is determined by the NMLS system.
• All of the requirements needed for licensure (background check, credit report, and any disclosure explanations) must be met before the license application can be submitted. What can be completed afterward is any state specific documentation, national test (if necessary) and any state specific PE. These final three items can be met once the approval is given by NMLS to operate under this new temporary authority regime. Also please note that these final three items need to be completed as soon as possible after the temporary authority is given as the state has up to 120 days to make a decision on the loan officer’ application whether to accept or deny.
The scenario above does not apply to loan officers who have had a previous license application denied, a previous license revoked or suspended, a cease and desist order or any type of misdemeanor or felony conviction.
This new ability has several benefits to you subject to the conditions listed above:
• You will be able to hire a high producing loan officer from a bank, and that loan officer can start originating pretty much right away as long as the conditions above are met.
• You will be able to hire a high producing loan officer from a competitor who can also start pretty much right away.
In each of the two situations above, the recruited person does not need to worry about being in a position of waiting anywhere from one to four months for an approval before starting to originate for the new employer. They can start right away.”

Please let us know if you have any questions.

 

Happy Holidays.

Nelson A. Locke, Esq.

Compliance Services USA

(800) 656-4584

 

 

Settlement Service Providers List is an important part of your Loan Estimate Package.

November 5th, 2019

Settlement Service provider List ( called the SPL) must be provided with your loan estimate. Here are the current requirements.

  1. Must be given at time of application or within three days of application.
  2.  Must identify AT LEAST ONE PROVIDER for each service disclosed in section c of your LE.
  3.  You can bundle, but you must say what is included in the bundle.
  4.  The provider you name must be local to the property and able to complete the service.
  5.  If you have an ownership interest in a service provider, you must also provide the affiliated business arrangement disclosure.  “Sharing a financial benefit, etc.”
  6.  The SPL must be separate from the LE.
  7.  Has to include service provider name, estimate of costs (matching the LE) and name address and other contact information.

Confused? Just call us or email us for help. We are a compliance services firm run by former underwriters and originators, with attorney supervision. No guesses here.

Sincerely,

 

Nelson A. Locke, Esq

(800) 656-4584

www.lockelaw.us

 

 

Florida Mortgage Professionals Take Note

July 30th, 2019

Taken from an OFR Audit Letter dated last week.

“For the Examination Period, the Mortgage Brokerage Transaction and Lending Journal, Form OFR-494- 10 or HMDA-LAR; a listing of all applications by Loan Officer; and a listing of all Mortgage Loan Modification Applications.

SPECIFY IF ANY FUNDED/CLOSED LOANS IN THE MORTGAGE BROKERAGE
TRANSACTION & LENDING JOURNAL ARE FOR INVESTMENT/BUSINESS PROPERTIES.”

If you have fooled yourself into believing you could package what would otherwise be a QM or non-QM residential loan into a non-QM loan deeded to an LLC or Corp, be warned.

Nelson A. Locke, Esq.

Compliance Services, USA

800-656-4584