Which of the following entities is EXEMPT from licensing under the California Residential Mortgage Lending Act (CRMLA)?
Correct Answer
C) A nationally chartered bank regulated by the OCC
Nationally chartered banks regulated by the OCC, as well as state-chartered banks and credit unions, are exempt from CRMLA licensing. Federal preemption and existing regulatory oversight provide the basis for this exemption.
Why This Is the Correct Answer
Nationally chartered banks regulated by the OCC, as well as state-chartered banks and credit unions, are exempt from CRMLA licensing. Federal preemption and existing regulatory oversight provide the basis for this exemption.
Why the Other Options Are Wrong
Option A: A private mortgage company headquartered in California
Private mortgage companies are non-bank entities that must obtain CRMLA licenses to make residential mortgage loans in California.
Option B: An independent mortgage broker originating loans in California
Independent mortgage brokers are not exempt. If they engage in mortgage lending (not just brokering), they need a CRMLA license.
Option D: A non-bank correspondent lender operating in California
Non-bank correspondent lenders must be licensed under the CRMLA to operate in California.
Memory Technique
CA -> ca-crmla-lenders-servicers-bonds-net-worth-servicing
Exam Tip
CRMLA questions usually turn on lender versus servicer authority, branch authority, $250,000 net worth, surety bond coverage, servicing duties, DFPI oversight, and exemptions for regulated depository institutions.
Common Mistakes to Avoid
- -Using a national baseline answer when California has agency-specific DFPI or DRE requirements
- -Confusing CFL, CRMLA, covered-loan, usury, servicing, and DRE endorsement rules
- -Relying on legacy California state-exam or education assumptions instead of current NMLS source pages
More UST Questions
In a pricing desk question, an audit analyst sees facts tied to Prohibited Misrepresentation. What should the file reflect?
An applicant previously had an MLO license revoked by a state regulator. Under the SAFE Act minimum standards for a new state-licensed MLO license, which statement is correct?
Which statement correctly distinguishes a license suspension from a license revocation?
A state regulator has issued an order suspending an MLO's authority effective immediately. The MLO has filed an appeal, but no stay has been granted. What should the MLO do?
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Why does NMLS maintain licensing and enforcement information that participating regulators can access?
A regulator issues a final license suspension without giving the MLO notice of the alleged violation or any opportunity to respond, even though applicable law requires both. What issue is presented?
A regulator finds that an MLO charged consumers prohibited fees. Which set of actions is consistent with the enforcement tools contemplated by Regulation H?
An MLO's license status in NMLS changes to suspended, with no stay or reinstatement shown. What is the immediate operational effect?
Which fact most directly supports disciplinary action against an MLO rather than merely a request for additional application information?
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