A Washington loan originator takes a borrower check for an appraisal in 2026 and banks it in a personal account overnight. Does temporarily depositing the appraisal check in a personal account satisfy the limited transfer permission?
Correct Answer
B) Prohibited: an originator may transfer such funds but never hold them
A loan originator may not solicit or receive fees for a third-party provider, except that the originator may transfer funds from a borrower to a licensed or exempt mortgage broker or to the third-party provider, if the originator does not deposit, hold, retain or use the funds for any purpose other than paying bona fide third-party fees. Other choices: arriving the next day does not undo the deposit; a record of the transfer is not the condition; and earning interest is not what the prohibition turns on. Source: RCW 19.146.070(3)
Why This Is the Correct Answer
A loan originator may not solicit or receive fees for a third-party provider, except that the originator may transfer funds from a borrower to a licensed or exempt mortgage broker or to the third-party provider, if the originator does not deposit, hold, retain or use the funds for any purpose other than paying bona fide third-party fees. Other choices: arriving the next day does not undo the deposit; a record of the transfer is not the condition; and earning interest is not what the prohibition turns on. Source: RCW 19.146.070(3)
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