CFPB Interpretive Rule Regarding Screening and Training Requirements for Individual Mortgage Loan Originators with Temporary Authority to Originate Consumer Mortgage Loans

In Client and Friends Memos by BMG Memorandum

In the November 19, 2019, issue of the Federal Register (84 FR 63791) the Consumer Financial Protection Bureau (CFPB) issued an Interpretive Rule concluding that a loan originator organization is not required to comply with the screening and training requirements in §1026.36(f)(3) of Regulation Z for an individual loan originator employee authorized to act as a loan originator pursuant to the temporary authority described in the Mortgage Licensing Act of 2008 (SAFE Act) as amended by the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018 (EGRRCPA, Public Law 115-174, Section 106, see attachment). These amendments permit certain individuals who were previously registered or State-licensed for a certain period of time pursuant to the SAFE Act to act as a loan originator in a State, if they have applied for a loan originator license in that State pursuant to the temporary authority described in the SAFE Act.


Full Memorandum