Mortgage Loan Originator Required Training Series – Part 3
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 THREE in the quarterly series will focus on the end of the “mortgage life cycle: and the requirements when the loan application has been approved,approved not accepted, denied, or withdrawn. How do you close an approved mortgage loan request? What documents are required? What appraisal copy rules must be followed prior to closing? What procedures must be followed for Regulation B, Z, RESPA, HMDA, and Flood? There are additional “post closing” requirements to correctly report the transactions on the HMDA LAR.
- What disclosures are required for TILA (Regulation Z) and RESPA at closing? What are the special rules for closing an HPML and a High-Cost Mortgage?
- What rescission rules must be followed? When do they apply?
- What are the appropriate notifications for denied loans? How should approved, not accepted and withdrawn loan applications be documented?
- Review of the Loan Disclosure and common mistakes; tolerance reviews and reimbursement rules
- HMDA reporting review
- Flood Determination Process and calculation examples
- How will you prove that the loan originators have sufficient knowledge for their job responsibilities?
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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