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A manager at a Delaware originating entity supervises MLOs but does not communicate directly with customers. Under Delaware’s definition page, how is the manager treated?

Correct Answer

C) The manager is not deemed an MLO solely on that supervisory role

Delaware states that an officer or manager that supervises MLO activities and does not communicate directly with customers is not included in the MLO definition on that basis.

Answer Options
A
The manager is automatically an MLO because all supervisors are MLOs
B
The manager must be an MLO because customer communication is irrelevant
C
The manager is not deemed an MLO solely on that supervisory role
D
The manager becomes an MLO only because the company is an originating entity

Why This Is the Correct Answer

The manager is not deemed an MLO solely on that supervisory role is correct. Delaware states that an officer or manager that supervises MLO activities and does not communicate directly with customers is not included in the MLO definition on that basis. Delaware states that an officer or manager that supervises MLO activities and does not communicate directly with customers is not included in the MLO definition on that basis.

Why the Other Options Are Wrong

Option A: The manager is automatically an MLO because all supervisors are MLOs

Delaware provides an exclusion for certain non-customer-facing supervisors.

Option B: The manager must be an MLO because customer communication is irrelevant

Customer communication is relevant to the exclusion stated by Delaware.

Option D: The manager becomes an MLO only because the company is an originating entity

The company’s status alone does not erase the stated exclusion.

Memory Technique

DE-C025 -> Delaware-definitions-and-exemptions

Exam Tip

Supervision without direct customer communication is a Delaware definition trap.

Common Mistakes to Avoid

  • -Importing another state requirement into Delaware
  • -Confusing NMLS baseline requirements with Delaware-specific rules
  • -Treating operational assumptions as legal authority
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