A processor at a brokerage collects documents, orders 3 verifications and answers borrower questions about what the file still needs. She never quotes a rate or discusses terms. If she is an employee performing only clerical work under a licensed originator's direction and supervision, do these activities alone require an individual MLO license under the federal SAFE minimums?
Correct Answer
C) No: the stated employee duties are only supervised clerical support
C. The stipulated supervised employee support work does not alone require this license. The question restricts her duties to obtaining file information under licensed supervision. Borrower contact to obtain processing information is different from taking applications or offering terms. Scope and exceptions: Actual duties and employment status matter. Independent-contractor processing, broader state rules or activities beyond the premise need separate review; no universal compensation exemption is implied. Source: Section 1008.103(d), (e)(3)–(4) — https://www.consumerfinance.gov/rules-policy/regulations/1008/103/ Clerical or support duties definition — https://www.consumerfinance.gov/rules-policy/regulations/1008/23/
Why This Is the Correct Answer
C. The stipulated supervised employee support work does not alone require this license. The question restricts her duties to obtaining file information under licensed supervision. Borrower contact to obtain processing information is different from taking applications or offering terms. Scope and exceptions: Actual duties and employment status matter. Independent-contractor processing, broader state rules or activities beyond the premise need separate review; no universal compensation exemption is implied.
Why the Other Options Are Wrong
Option A: A license is needed because she works at a brokerage rather than a bank
Brokerage employment alone does not eliminate the stated support exclusion.
Option B: A license is needed: any 1 of the 3 contacts is origination
A contact count does not define origination.
Option D: No license is needed only where she is paid a salary rather than per file
A salary is not the sole test for the stipulated support role.
Exam Tip
Apply the complete support-role conditions, not just the job title.
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