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Ethics & Fraudeasy17% of exam

An MLO's former colleague, now working at a different lender, asks for contact information of previous mutual clients who might be interested in refinancing. The colleague promises to share referral fees. What is the primary violation?

Correct Answer

C) Disclosure of nonpublic personal information without consent

While referral fee issues may also apply, the primary violation is sharing borrower contact information (nonpublic personal information) without proper consent under the Gramm-Leach-Bliley Act. Client information cannot be shared with competitors for solicitation purposes.

Answer Options
A
Improper referral fee arrangement under RESPA
B
Unlicensed mortgage loan origination activity
C
Disclosure of nonpublic personal information without consent
D
Violation of fair lending practices

Why This Is the Correct Answer

While referral fee issues may also apply, the primary violation is sharing borrower contact information (nonpublic personal information) without proper consent under the Gramm-Leach-Bliley Act. Client information cannot be shared with competitors for solicitation purposes.

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