September 2008 Mortgage Licensing Update

With the mortgage crisis still in full force, many statescontinuing education, as specified in the amendments,
are looking for a way to increase regulation on theto "covered employees."
mortgage industry. The first step to regulatingThe new regulations became effective on August 10,
mortgage companies is to license the companies and2008. Under the new regulation, mortgage licensees
their sales people. Many new states have passedare responsible for providing initial training and continuing
regulations this month requiring additional licensing.education to their covered employees on at least an
North Carolina Passes New Mortgage Laws, Banningannual basis with respect to all laws and regulations
YSP and Requiring Licensing for Servicersapplicable to the licensees' business.
Effective October 1, 2008, House Bill 2188 amends theInitial education must consist of at least twelve (12)
Rate Spread Home Loan Law to prohibit the paymenthours relating to applicable federal laws and regulations,
of a yield spread premium on rate spread home loans.at least four (4) hours of which must relate to
Make sure to look at the definition of a rate spreadapplicable Virginia laws and regulations, and two (2)
home loan. Effective January 1, 2009, House Bill 2463hours must relate to mortgage fraud prevention,
amends the Mortgage Lending Act to require theincluding penalties for participating in mortgage fraud.
licensure of mortgage loan servicers.Initial education shall be provided to individuals who
Delaware Requires Loan Originator Licensingwere covered employees as of July 1, 2008 on or
Effective January 1, 2009, Loan Originators will bebefore May 1, 2009, and to individuals who become
required to be licensed in Delaware. HB 508 defines acovered employees after July 1, 2008, within 90 days
mortgage loan originator as an employee orof their date of hire. Continuing education must consist
independent contractor of a licensed Delawareof at least four (4) hours related to applicable federal
Mortgage Broker or Lender. The legislation requires alaws and regulations, at least two (2) hours related to
mortgage loan originator to apply to the Office of theapplicable Virginia laws and regulations, and at least
State Bank Commissioner for a mortgage loanone (1) hour relating to mortgage fraud prevention,
originator license, establishes initial and continuingincluding penalties for participating in mortgage fraud.
education requirements for licensees, and authorizesAdditionally, the regulation prohibits licensees from hiring
the Commissioner to adopt regulations to facilitateany individual for a position of employment who may
participation in the Nationwide Mortgage Licensinghave access to personal identifying information or
System. Delaware House Bill 508 becomes effectivefinancial information to any customer, without first
on January 1, 2009, but mortgage loan originators willobtaining a criminal history record from the Central
not be required to obtain a license until the State BankCriminal Records Exchange that shows the
Commissioner adopts regulations implementing theprospective employee has not been convicted in any
new licensing laws. The bill requires that loan originatorcourt of any felony, or any misdemeanor involving
licensees have at least 18 hours of education coursesfraud, misrepresentation, or deceit under the laws of
within the five years prior to licensure, or within oneany state or the United States.
year following licensure. Applicants may work asFlorida Bars Criminals from Mortgage Licensing
mortgage loan originators upon initial employment on aFlorida approved an emergency rule change to ban
temporary basis until the person is either licensed orindividuals with criminal histories from obtaining licenses
the application is denied. Applicants must submit ato work in the mortgage industry. The rule prohibits the
$250 investigation fee and a $250 annual license fee.Florida Office of Financial Regulation from issuing a
Virginia Amends Regulations to Require Initial andFlorida mortgage broker, mortgage lender,
Continuing Educationcorrespondent lender or mortgage brokerage business
The Virginia State Corporation Commission recentlylicense to an applicant for a specified period (ranging
issued amendments to regulations implementing thebetween 5 to 15 years) if the applicant or "relevant
Mortgage Lender and Broker Act. The newpersons" of the applicant (i.e., officers, directors,
regulations: (i) require licensees to conduct backgroundmembers, partners, control persons and joint
checks; (ii) prohibit licensees from hiring an individualventurers) have been found or pled guilty or no
who has been convicted of a felony or acontest to various felonies or misdemeanors. The rule
misdemeanor involving fraud, misrepresentation, orallows for mitigating factors that could lengthen or
deceit, without obtaining prior approval from theshorten the periods of ineligibility. The emergency rule
Commission of the Bureau of Financial Institutions; andwill remain in effect until regular rulemaking is
(iii) make licensees responsible for providing initial andcompleted.