I recently saw a post on another website that expressed the blogger's feeling that the playing field for MLOs was not level as between MLOs who are required to be licensed and participate in continuing education annually and renew their licenses annully, as opposed to those MLOs who work for depository institutions basically which are regulated by federal banking agencies. The list of MLOs who are exempt from licensure under the standards here in CT are set forth by the CT Department of Banking. The MLOs that are exempt from licensure through the NMLS must nonetheless register with NMLS. I am not aware of the cost for registration although I would imagine that it is not free. The difference basically comes down to the fact that a registered MLO who works for a depository institution that is regulated by a federal banking agency is not required to renew his or her license every year and take continuing education courses every year.
The MLOs and other individuals who work for our company who are required to be licensed were offered discounted fees for continuing education courses. Continuing education is in fact a benefit rather than a
pain in the neck as it keeps you up-to-date on new regulations which are changing almost daily it seems. So, I really don't mind the CE requirement especially when we are offered discount courses by NMLS approved course providers. Otherwise, to renew licences in CT for an MLO costs about $380 a year plus a fee of about $35 every three years for new fingerprints. Total cost is just about $500 after the first year of being a licensed MLO. Yeah, it does put a dent in the November / December cash flow, but it is manageable with a little advance planning.
MLOs at depository institutions are still required to follow the same regulations that are set for in TILA, RESPA, etc. They do not get a pass on playing by those rules. Big box banks must still play by the rules that apply to small mortgage brokerage companies that are non-depository institutions or companies. So there does not appear to be anything unlevel about the playing field in that regard.
I have never liked the idea of working for big companies or other institutions that are impersonal and where you cannot be yourself. I have always worked at smaller businesses where I have more freedom to come and go pretty much as I please as long as I get my work done and carry my own weight. I doubt that a big box bank MLO has the ability to enjoy that kind of freedom. That alone to me is worth the hassle of having to renew my license every year. I just don't see the playing field as being unlevel as between licensed MLOs and registered MLOs that work for depository institutions regulated by some federal banking regulatory agency. If anything, I think the registered MLOs are the ones on the short end of things. Dealing with federal regulators can be nerve wracking and just plain difficult. Just my thoughts.
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