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An assistant collects documents, orders 12 appraisals and schedules closings, and never discusses rates or terms with a borrower. Assuming she is a supervised employee performing only clerical support, do these tasks themselves require an individual MLO license?

Correct Answer

C) No license needed: administrative and clerical work falls outside the rule

Administrative or clerical tasks are outside what requires an originator license: the license attaches to taking an application or offering or negotiating terms. Other choices: proximity to the files is not the test; no file count triggers it; and supervision is not what makes clerical work clerical. Source: 12 CFR 1008.103; Cal. Fin. Code § 22013

Answer Options
A
A license is needed once she has worked on more than 10 files a month
B
No license is needed only while a licensed originator reviews all of her work
C
No license needed: administrative and clerical work falls outside the rule
D
A license is needed, because she does work on residential mortgage files daily

Why This Is the Correct Answer

Administrative or clerical tasks are outside what requires an originator license: the license attaches to taking an application or offering or negotiating terms. Other choices: proximity to the files is not the test; no file count triggers it; and supervision is not what makes clerical work clerical. Source: 12 CFR 1008.103; Cal. Fin. Code § 22013

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