Mortgage Loan Originator Required Training Series – Part 1
Will you be able to prove compliance with this Regulation Z training requirement in 2015 for loan originators in the next compliance exam?
Commentary to 1026.36(f)(3)(iii)
Training. The periodic training required in § 1026.36(f)(3)(iii) must be sufficient in frequency, timing, duration, and content to ensure that the individual loan originator has the knowledge of State and Federal legal requirements that apply to the individual loan originator’s loan origination activities.
The training must take into consideration the particular responsibilities of the individual loan originator and the nature and complexity of the mortgage loans with which the individual loan originator works. An individual loan originator is not required to receive training on requirements and standards that apply to types of mortgage loans that the individual loan originator does not originate, or on subjects in which the individual loan originator already has the necessary knowledge and skill.
Session One in the quarterly series will focus on the Reg B requirements for the life of the loan including the application process, monitoring information, and provision of appraisal/valuation copies and disclosures. Additional information will be included for applications covered by HMDA and RESPA.
Note: Additional sessions in the series are scheduled for August 18, and November 3rd.
- Reg B requirements for the life of the loan; how to take and process an application. This will include the proper collection of monitoring information.
- Model application forms – which application form should be used for various types of loans?
- What’s the difference between an inquiry, pre-qualification, and application? What regulations are triggered for each scenario?
- Appraisal and “other valuation” requirements of 1002.14
- Monitoring information for HMDA at time of application; preview of the proposed changes in HMDA coverage
- Required disclosures for appraisal notices
- Definitions under 1002.14, rules for E-Sign compliance
- Providing appraisal copies, timing requirements and exceptions for waivers
- PREVIEW – Applications taken on or after August 1, 2015 will be covered by the new “Integrated Disclosure” provisions. This session will include an overview of the impacts of the changes in disclosures & timing requirements.
- BONUS – Participants will receive a 10 question quiz and an answer key. Passing the quiz will provide documentation of the effectiveness of the training effort.
This informative session will benefit mortgage loan originators, loan officers, loan assistants, loan operations staff, compliance officers, auditors, and trainers.
Susan Costonis is a compliance consultant and trainer. She frequently provides consulting services to financial institutions regarding fair lending and other compliance management issues. Her 37 year career in banking and training began with 20 years at First National Bank, an affiliate of Wells Fargo Bank, in Fort Collins, CO. Susan has been a bank compliance consultant or compliance officer in Louisiana since 1998.
During her career, Susan has successfully managed compliance programs and exams for institutions supervised by the OCC, FDIC, and Federal Reserve. She is a Certified Regulatory Compliance Manager and completed the ABA Graduate Compliance School and the Graduate Banking School of the University of Colorado. Susan regularly presents seminars to financial associations.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2.5 CE Credits
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