SAFE MLO MLO Reddit Questions

The Fair Credit Reporting Act (FCRA) restricts the permissible purposes for which a credit report can be obtained. A mortgage loan originator may only pull a credit report for a bona fide mortgage loan transaction. Pulling a credit report for a non-mortgage transaction, even with the consumer’s consent, is not a permissible purpose.

“A person may obtain a consumer report only if the report is to be used for a permissible purpose under the FCRA. Permissible purposes include credit transactions initiated by the consumer.”

— 15 U.S.C. § 1681b; FCRA

Mortgage loan originators (MLOs) are required to complete 8 hours of continuing education (CE) annually to maintain their license under the SAFE Act (Secure and Fair Enforcement for Mortgage Licensing Act). This is mandatory to ensure that MLOs stay updated with changing regulations, compliance requirements, and industry practices.

The 8 hours must include specific coursework, typically:

3 hours of federal law and regulations

2 hours of ethics (covering fraud, consumer protection, etc.)

2 hours of non-traditional mortgage lending

1 hour of elective content that may vary depending on state requirements.

Failure to meet these CE requirements can result in license suspension or revocation.

With an interest-only mortgage, the borrower makes payments that cover only the interest for a set period (such as 5 or 10 years). After this period, the borrower begins paying both principal and interest, which causes payments to increase.

“An interest-only mortgage is a loan with scheduled payments that for a period of time require payment of interest only, with no reduction of the principal balance.”

— CFPB, Consumer Handbook on Adjustable-Rate Mortgages; SAFE MLO National Test Study Guide

When responding to a state regulator’s request regarding a consumer complaint, the company should provide all requested documents, along with an explanation of the facts and what caused the complaint. Regulators have authority to access unredacted information as part of their oversight and investigative powers.

“Regulators have the right to access all pertinent documentation in the course of investigations or examinations. Companies should provide a full and factual response, including all supporting documentation and their explanation of events.”

— SAFE Act, 12 U.S.C. § 5117; NMLS Policy Guidebook