MLO v LO - Who Has to Do What?


Presented by: Jack Holzknecht and Mary Beth Guard

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WHAT Regulations implementing the Secure and Fair Enforcement for Mortgage Licensing Act (SAFE Act) were effective on October 1, 2010. Among other requirements the SAFE Act requires mortgage loan originators (MLO) to register with the National Mortgage Licensing System and Registry (NMLSR). Revisions to Regulation Z, which were effective on April 1, 2011, prohibit certain acts and practices involving loan originators (LO). Significant clarification and expansion to the Regulation Z rules occurred in January 2014.

There is ample evidence that much confusion exists regarding who is or is not a MLO or a LO. Financial institutions have generally identified MLOs, gotten them registered and have maintained the registration over the past few years. But a number of financial institutions have failed to identify all employees performing the duties of a MLO, and as a result those employees have not been registered with the NMSLR. LOs are much more plentiful than MLOs. We are aware of numerous cases where financial institutions have not identified all of their LOs and have not met the numerous requirements applicable to LOs.

Misidentification leads to violations. The action needed to assure compliance with the SAFE Act and the action needed to assure compliance with the TIL requirements differ significantly. This program clarifies who is a MLO and who is a LO. It also clearly describes the requirements and limitations applicable to MLOs and LOs. It is fair to say that all MLOs are LOs, but the definition of LO includes many involved in the mortgage lending function who are not, and never will be, MLOs. This program is well placed on the calendar. Have you assured your MLOs have completed their annual renewal? Have your LOs received the required periodic training required by Regulation Z?

Most creditors have adopted procedures governing the actions of MLOs and LOs. But when an individual is not identified as a MLO or LO, the procedures are not applied and violations result. Every financial institution needs to reevaluate their process for identifying which employees are MLOs, which are LOs, and who is not subject to either set of rules.

CONTENT Upon completion of the program participants will understand:
  • Who is and who is not a MLO;
  • Who is and who is not a LO;
  • Requirements and restrictions applicable to a MLO including:
    • Initial registration;
    • Annual renewal;
    • Use of the unique identifier;
  • Requirements and restrictions apply to a LO including:
    • Compensation rules;
    • Qualifications;
    • Required periodic training; and
    • NMSLR ID on documents.
Who Should Attend
The program is designed for compliance officers, human resource managers, management of mortgage loan departments, auditors and others involved in hiring, training and managing loan department employees.

About the Speakers: Jack Holzknecht is a principal with Pegasus Educational Services, LLC. He has been delivering the word on lending compliance for 38 years. In 33 years as a trainer over 125,000 bankers (and many examiners) have participated in Jack's live seminars and webinars. Jack's career began in 1976 as a federal bank examiner. He later headed the form, software and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by several state bankers associations. He developed and delivered compliance training for the FDIC for ten years. Jack is a Certified Regulatory Compliance Manager and a member of the National Speakers Association. He is also a BOL Guru.

Mary Beth Guard currently serves as Executive Editor of, CEO of Glia Group, Inc. and Executive Editor of Since graduating from law school in 1980, Mary Beth has focused her work almost exclusively on the banking industry. Previously, Mary Beth served as EVP/General Counsel and COO for the Oklahoma Bankers Association, EVP of Specialized Services for Thomson Financial Publishing, and General Counsel for the Oklahoma State Banking Department. Mary Beth is on the advisory board for Bankers' Hotline. She has presented training programs for virtually every major national financial industry association, as well as more than a dozen state bankers associations and a host of other organizations. In addition, Mary Beth has written more than a thousand banking-related articles and is a BOL Guru.

This program was recorded in its entirety in November 2014. The CD-ROM includes program slides, materials (if available) and follow-up Q & A document.

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  • Model: cd_mlo1114
  • Manufactured by: Glia Group, Inc.

This product was added to our catalog on Tuesday 09 September, 2014.

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