[Federal Register Volume 84, Number 223 (Tuesday, November 19, 2019)]
[Rules and Regulations]
[Pages 63791-63794]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-24944]



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 Rules and Regulations
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 This section of the FEDERAL REGISTER contains regulatory documents 
 having general applicability and legal effect, most of which are keyed 
 to and codified in the Code of Federal Regulations, which is published 
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  Federal Register / Vol. 84, No. 223 / Tuesday, November 19, 2019 / 
Rules and Regulations  

[[Page 63791]]



BUREAU OF CONSUMER FINANCIAL PROTECTION

12 CFR Part 1026


Truth in Lending (Regulation Z); Screening and Training 
Requirements for Mortgage Loan Originators With Temporary Authority

AGENCY: Bureau of Consumer Financial Protection.

ACTION: Interpretive rule.

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SUMMARY: This interpretive rule construes the Bureau's Regulation Z, 
which implements the Truth in Lending Act (TILA). Generally, if a 
mortgage loan originator organization employs an individual loan 
originator who is not licensed and is not required to be licensed, 
Regulation Z requires the loan originator organization to perform 
specific screening of that individual before permitting the individual 
to act as a loan originator and to provide certain ongoing training. 
Regulation Z is ambiguous as to whether these requirements apply to 
loan originator organizations employing individual loan originators who 
have temporary authority to originate loans pursuant to the Economic 
Growth, Regulatory Relief, and Consumer Protection Act of 2018 
(EGRRCPA) amendments to the Secure and Fair Enforcement for Mortgage 
Licensing Act of 2008 (SAFE Act). These amendments take effect on 
November 24, 2019. This interpretive rule concludes that a loan 
originator organization is not required to comply with certain 
screening and training requirements under Regulation Z if the 
individual loan originator employee is authorized to act as a loan 
originator pursuant to the temporary authority described in the SAFE 
Act.

DATES: This interpretive rule is effective on November 24, 2019.

FOR FURTHER INFORMATION CONTACT: Terry J. Randall, Senior Counsel, 
Office of Regulations, at 202-435-7700 or https://reginquiries.consumerfinance.gov/. If you require this document in an 
alternative electronic format, please contact 
[email protected].

SUPPLEMENTARY INFORMATION:

I. Discussion

    In 2010, the Dodd-Frank Wall Street Reform and Consumer Protection 
Act (Dodd-Frank Act) added TILA section 129B(b)(1), and imposed new 
requirements for loan originators, including the requirement for them 
to be qualified.\1\ In 2013, the Bureau adopted amendments to 
Regulation Z, implementing the mortgage loan originator qualification 
requirements under TILA. These Regulation Z changes including adding 
Sec.  1026.36(f)(3), which generally requires a loan originator 
organization that employs an individual loan originator who is not 
licensed and is not required to be licensed pursuant to the SAFE Act 
to: (1) Complete certain screenings of that individual prior to 
permitting the individual to act as a loan originator on a consumer 
credit transaction secured by a dwelling, and (2) to provide periodic 
training.\2\ In adding these requirements, the Bureau took into account 
the SAFE Act's preexisting screening and training requirements for loan 
originators.\3\
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    \1\ Public Law 111-203, sec, 1402(a)(2), 124 Stat. 1376, 2139 
(2010) (codified at 15 U.S.C. 1639b).
    \2\ Loan Originator Compensation Requirements under the Truth in 
Lending Act (Regulation Z), 78 FR 11279, 11374-84, 11412-13 (Feb. 
15, 2013) (promulgating 12 CFR 1026.36(f)(3)), amended 78 FR 60382, 
60441-42 (Oct. 1, 2013). These requirements do not apply to loan 
originator organizations that are government agencies or State 
housing finance agencies. 12 CFR 1026.36(f).
    \3\ 78 FR at 11375.
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    The EGRRCPA amendments to the SAFE Act take effect on November 24, 
2019.\4\ These amendments permit certain individuals who were 
previously registered or State-licensed for a certain period of time 
pursuant to the SAFE Act to act as a loan originator in a State, if 
they have applied for a loan originator license in the State (``loan 
originators with temporary authority'').\5\
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    \4\ Public Law 115-174, title I, sec. 106(a), 132 Stat. 1296, 
1302 (2018) (to be codified at 12 U.S.C. 5117).
    \5\ 12 U.S.C. 5117.
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    Section 1026.36(f)(3) of Regulation Z is ambiguous as to whether 
its screening and training requirements for loan originator 
organizations employing individual loan originators who ``are not 
licensed and are not required to be licensed'' apply to a loan 
originator organization employing a loan originator with temporary 
authority. As discussed below, the Bureau believes that interpreting 
these requirements not to apply is consistent with Congress's 
objectives in amending the SAFE Act. The Bureau also believes that 
interpreting these requirements not to apply is consistent with the 
agency's objectives in imposing the screening and training requirements 
in Sec.  1026.36(f)(3). Accordingly, the Bureau concludes that if an 
individual loan originator has temporary authority in a particular 
State, the loan originator organization does not need to satisfy the 
screening and training requirements in Sec.  1026.36(f)(3) with regard 
to that individual's loan origination activities in that State.
    The Bureau is issuing this interpretive rule based on its authority 
to interpret Regulation Z, including under section 1022(b)(1) of the 
Dodd-Frank Act, which authorizes guidance as may be necessary or 
appropriate to enable the Bureau to administer and carry out the 
purposes and objectives of the Federal consumer financial laws.\6\
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    \6\ 12 U.S.C. 5512(b)(1). The relevant provisions of Regulation 
Z form part of Federal consumer financial law. 12 U.S.C. 
5481(12)(O), (14).
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    By operation of TILA section 130(f), no provision of TILA sections 
130, 108(b), 108(c), 108(e), or 112 imposing any liability applies to 
any act done or omitted in good faith in conformity with this 
interpretive rule, notwithstanding that after such act or omission has 
occurred, the interpretive rule is amended, rescinded, or determined by 
judicial or other authority to be invalid for any reason.\7\ The Bureau 
plans to incorporate the content of this interpretive rule into the 
Official Interpretations to Regulation Z at a later date.\8\
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    \7\ 15 U.S.C. 1640(f).
    \8\ 12 CFR part 1026, supp. I.
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Screening and Training for Licensed Loan Originators Under the SAFE Act

    The SAFE Act prohibits individuals from engaging in the business of 
a loan originator unless they are registered loan originators under 
Federal law or they obtain a State loan originator license and 
registration.\9\ The SAFE Act requires loan originators who are 
employees of a depository institution,

[[Page 63792]]

employees of a subsidiary that is owned and controlled by a depository 
institution and regulated by a Federal banking agency, or employees of 
an institution regulated by the Farm Credit Administration (FCA) 
(``registered loan originators'') to register with the Nationwide 
Mortgage Licensing System and Registry (NMLSR).\10\ (The NMLSR is a 
system for registering, licensing, supervising, and tracking loan 
originators).
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    \9\ 12 U.S.C. 5103(a)(1).
    \10\ See 12 U.S.C. 5106.
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    The SAFE Act also generally requires loan originators who are not 
registered loan originators to obtain a State license and to register 
with the NMLSR (``licensed loan originators'').\11\ SAFE Act licensing 
is implemented by States. To grant an individual a SAFE Act-compliant 
loan originator license, section 1505 of the SAFE Act, 12 U.S.C. 5104, 
requires the State to conduct certain screening and to ensure that the 
loan originator has completed certain education and testing 
requirements. Generally speaking, section 1505 provides that the State 
must determine that the individual has never had a loan originator 
license revoked; has not been convicted of enumerated felonies within 
specified timeframes; has demonstrated financial responsibility, 
character, and fitness; has completed 20 hours of pre-licensing 
education that the NMLSR has approved; has passed a written test the 
NMLSR has approved; and has met net worth or surety bond requirements. 
Licensed loan originators also must take eight hours of continuing 
education classes the NMLSR has approved and must renew their licenses 
annually.\12\ States may impose additional or higher minimum standards 
for licensing of individual loan originators under their SAFE Act-
compliant licensing regimes.\13\
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    \11\ 12 U.S.C. 5102(8) and (12). Regulation H, 12 CFR part 1008, 
which implements SAFE Act standards applicable to State licensing, 
provides that a State is not required to impose licensing and 
registration requirements on certain individuals. 12 CFR 
1008.103(e).
    \12\ 12 U.S.C. 5105. In addition to other requirements, the SAFE 
Act requires individuals who are subject to SAFE Act registration or 
State licensing to obtain a unique identification number from the 
NMLSR. 12 U.S.C. 5103(a)(2).
    \13\ 12 U.S.C. 5104 and 5105 (e.g., describing ``minimum 
standards'').
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    In contrast, the SAFE Act does not impose these specific screening 
or education requirements on registered loan originators. Section 1507 
of the SAFE Act, 12 U.S.C. 5106, generally requires the Bureau to 
develop and maintain a system for registering individual loan 
originators who are subject to registration. In connection with loan 
originator registration, the SAFE Act specifies that the following 
information must be furnished to the NMLSR: (1) Fingerprints to the 
NMLSR for a criminal history background check and (2) personal history 
and experience, including authorization for the NMLSR to obtain 
information related to any administrative, civil or criminal findings 
by any governmental jurisdiction.\14\
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    \14\ 12 U.S.C. 5106. In addition, Regulation G, 12 CFR part 
1007, which implements SAFE Act registration requirements, imposes 
an obligation on the employing covered financial institution, among 
other things, to adopt and follow written policies and procedures 
that establish a process for reviewing employee criminal history 
background reports, taking appropriate action consistent with 
applicable Federal law, including section 19 of the Federal Deposit 
Insurance Act (FDIA), 12 U.S.C. 1829, section 206 of the Federal 
Credit Union Act, 12 U.S.C. 1786(i), and section 5.65(d) of the Farm 
Credit Act of 1971, as amended, 12 U.S.C. 2277a-14(d), and complying 
with certain recordkeeping requirements. 12 CFR 1007.104(h). 
Regulation G defines ``covered financial institution'' to mean any 
national bank, member bank, insured State nonmember bank, savings 
association, Farm Credit System institution, or federally insured 
credit union as any such term is defined in 12 CFR 1007.101(c)(1). 
Regulation G also specifies that ``covered financial institution'' 
also includes a non-federally insured credit union that registers 
subject to the conditions of 12 CFR 1007.101(c)(3). 12 CFR 1007.102.
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Screening and Training for Unlicensed Loan Originators Under Regulation 
Z

    In 2010, the Dodd-Frank Act added TILA section 129B(b)(1), and 
imposed new requirements for loan originators, including the 
requirement for them to be qualified.\15\ In 2013, the Bureau amended 
Regulation Z to implement the requirement that they be qualified by, 
among other things,\16\ establishing certain screening and training 
requirements for unlicensed loan originators.\17\ If an individual loan 
originator is not required to be licensed and is not licensed, Sec.  
1026.36(f)(3) requires a loan originator organization to complete 
certain screening before permitting the individual to act as a loan 
originator in a consumer credit transaction secured by a dwelling and 
to provide periodic training. Generally, the loan originator 
organization must obtain: (1) A criminal background check about the 
individual; (2) a credit report, and (3) certain information from the 
NMLSR (or from the individual if the individual is not a registered 
loan originator) about any administrative, civil, or criminal findings 
by any government jurisdiction relating to the individual, and make 
substantially the same findings regarding the individual's criminal 
history, financial responsibility, character, and general fitness that 
the SAFE Act requires for State loan originator licenses.\18\ Loan 
originator organizations employing such individual loan originators 
must also provide periodic training for the loan originators about 
Federal and State legal requirements that apply to their loan 
origination activities.\19\
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    \15\ Public Law 111-203, sec. 1402(a)(2), 124 Stat. 1376, 2139 
(2010) (codified at 15 U.S.C. 1639b).
    \16\ In addition to the requirements described above, Sec.  
1026.36(f)(1) requires a loan originator organization to comply with 
all applicable State law requirements for legal existence and 
foreign qualification and Sec.  1026.36(f)(2) requires a loan 
originator organization to ensure that each individual loan 
originator who works for the loan originator organization is 
licensed or registered to the extent the individual is required to 
be licensed or registered under the SAFE Act, its implementing 
regulations, and State SAFE Act implementing law. The requirements 
in Sec.  1026.36(f)(1)-(3) do not apply to loan originator 
organizations that are government agencies or State housing finance 
agencies. 12 CFR 1026.36(f).
    \17\ 12 CFR 1026.36(f)(3). See also 78 FR at 11374-84.
    \18\ 12 CFR 1026.36(f)(3)(i) and (ii). Regulation Z excludes 
individual loan originators hired prior to January 1, 2014, from 
these requirements unless there were no applicable statutory or 
regulatory background standards in effect at the time of hire used 
to screen the individual or unless, based on reliable information 
known to the loan originator organization, the individual likely 
does not meet the standards in Sec.  1026.36(f)(3)(ii). 12 CFR 
1026.36(f)(3); comment 36(f)(3)(ii).
    \19\ 12 CFR 1026.36(f)(3)(iii).
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    When the Bureau issued Sec.  1026.36(f)(3), it generally applied 
only to registered loan originators and employees of bona fide 
nonprofit organizations that a State exempted from licensing under the 
criteria in Regulation H.\20\ It did not apply to loan originators that 
were also subject to individual screening by a State as part of the 
State's consideration of an application for a loan originator license. 
The Bureau intended to define certain minimum qualification standards 
for loan originators to allow consumers to be confident that loan 
originators meet core standards of integrity and competence, regardless 
of the type of institution for which they work.\21\
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    \20\ Comment 36(f)(3)-1 (``Individual loan originators who are 
not subject to SAFE Act licensing generally include employees of 
depository institutions and their Federally regulated subsidiaries 
and employees of bona fide nonprofit organizations that a State has 
exempted from licensing under the criteria in 12 CFR 
1008.103(e)(7).'').
    \21\ 78 FR at 11378.
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    Thus, by adopting Sec.  1026.36(f)(3), the Bureau established a 
scheme under which States perform screening of licensed loan 
originators and loan originator organizations generally perform the 
same screening of their unlicensed loan originator employees. 
Similarly, States ensure that licensed loan originators complete 
specific training and testing and loan originator organizations 
generally provide training

[[Page 63793]]

for unlicensed loan originator employees.

Loan Originators With Temporary Authority Under EGRRCPA

    The EGRRCPA amendments to the SAFE Act add a new category of loan 
originators, those with temporary authority, effective November 24, 
2019.\22\ The amendments, which are in a section of the EGRRCPA titled 
``Eliminating Barriers to Jobs for Loan Originators,'' among other 
things, permit certain loan originators to act as a loan originator in 
a State for a temporary period of time while applying for a license in 
the State. Eligible loan originators include those who are employed by 
a State-licensed mortgage company, have applied for a license in a new 
State, were previously registered or licensed in a different State for 
a certain period of time prior to applying for the new license, and 
satisfy certain criminal and adverse professional history criteria.\23\
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    \22\ Supra note 4.
    \23\ 12 U.S.C. 5117(b) and (c). Criminal history and adverse 
professional history criteria include that the individual has not 
had an application for a loan originator license denied, or a loan 
originator license revoked or suspended in any governmental 
jurisdiction; has not been subject to, or served with, a cease and 
desist order in any governmental jurisdiction or under section 
1514(c) of the SAFE Act, and has not been convicted of a misdemeanor 
or felony that would preclude licensure under the law of the 
application State. 12 U.S.C. 5117(b)(1) and (c)(1)(A).
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    The SAFE Act amendments grant loan originators who meet these 
criteria ``temporary authority to act as a loan originator in the 
application State'' for a specified period of time, beginning when an 
eligible individual submits certain application information and ending 
upon the occurrence of one of four specified events (e.g., the State 
grants the license).\24\ Thus, Congress chose to allow individuals who 
meet these criteria to engage in the business of a loan originator 
before the State had completed all of its processes for granting or 
denying an application for a loan originator license.
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    \24\ 12 U.S.C. 5117(b)(2) and (c)(2).
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Screening and Training Requirements Under Regulation Z for Loan 
Originator Organizations Employing Loan Originators With Temporary 
Authority

    As discussed above, Sec.  1026.36(f)(3) imposes certain screening 
and training obligations on loan originator organizations for ``each of 
its individual loan originator employees who [1] is not required to be 
licensed and [2] is not licensed as a loan originator pursuant to Sec.  
1008.103 of this chapter or State SAFE Act implementing law.'' \25\ 
This language is ambiguous regarding whether the individual loan 
originators that it references include loan originators with temporary 
authority.
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    \25\ 12 CFR 1026.36(f)(3). Generally, the loan originator 
organization must obtain the individual's criminal background check, 
a credit report, and certain information from the NMLSR (or from the 
individual if the individual is not a registered loan originator) 
about any administrative, civil, or criminal findings by any 
government jurisdiction, and make substantially the same findings 
regarding the individual loan originator's criminal history, 
financial responsibility, character, and general fitness that the 
SAFE Act requires for compliant State-issued loan originator 
licenses. 12 CFR 1026.36(f)(3)(i) and (ii). Loan originator 
organizations employing such individual loan originators must also 
provide periodic training on Federal and State legal requirements 
that apply to the individual loan originator's loan origination 
activities. 12 CFR 1026.36(f)(3)(iii).
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    Although it is ambiguous, the Bureau believes that the most 
appropriate interpretation of Sec.  1026.36(f)(3) is that it does not 
refer to a loan originator with temporary authority. A loan originator 
with temporary authority does not satisfy the first condition in Sec.  
1026.36(f)(3), because he or she is not an ``individual loan originator 
employee[ ] who is not required to be licensed . . . .'' He or she is 
an employee who is required to be licensed, although the employee can 
act as a loan originator while seeking the required license.
    The Bureau's interpretation of the ambiguous text of Sec.  
1026.36(f)(3) is based on the Bureau's expertise in understanding and 
carrying out the objectives of the SAFE Act and Regulation Z. First, 
interpreting Sec.  1026.36(f)(3) not to refer to loan originators with 
temporary authority would further Congress's objectives in amending the 
SAFE Act. The Bureau believes that Congress aimed to permit a loan 
originator that satisfies certain enumerated criteria and who is 
transitioning to a new State to be able to begin acting as a loan 
originator in the application State with minimal burden and delay and 
before the State has completed all of its processes relating to 
determining whether to grant a State license. This purpose is evident 
in the amendment's authorizing eligible loan originators to commence 
acting as a loan originator upon submitting certain application 
information and in the title of the relevant section of the EGRRCPA, 
``Eliminating Barriers to Jobs for Loan Originators.'' \26\ Requiring 
loan originator organizations to complete the Sec.  1026.36(f)(3) 
screening before permitting a loan originator with temporary authority 
to begin acting as a loan originator would impose an impediment on a 
loan originator from beginning to act as a loan originator, which would 
frustrate Congress's objective.
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    \26\ Supra note 4.
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    Likewise, Congress established different and less onerous 
qualification criteria for loan originators with temporary authority 
than those required by the SAFE Act for licensed loan originators. For 
example, the SAFE Act and Sec.  1026.36(f)(3) require a finding of 
financial responsibility before granting a State license or permitting 
an individual loan originator to act as a loan originator. The EGRRCPA 
amendments to the SAFE Act do not condition temporary authority on a 
finding concerning the individual's financial fitness. Applying through 
Regulation Z the same SAFE Act standards to loan originators with 
temporary authority would be in tension with Congress's decision to 
apply less onerous qualification criteria to these loan originators. 
The Bureau believes that it is most appropriate to instead read 
Regulation Z in a manner that aligns with Congress's objectives in the 
SAFE Act, by not imposing the relevant Regulation Z requirements on 
loan originators with temporary authority.
    A second and independently sufficient reason for interpreting Sec.  
1026.36(f)(3) to not include loan originators with temporary authority 
is that this reading is more consistent with the scheme for loan 
originator screening and training established by the Bureau. As the 
Bureau explained when adopting Sec.  1026.36(f)(3), the Bureau sought 
to implement TILA section 129B(b)(1)'s requirement that, subject to 
regulations prescribed the Bureau, each loan originator be 
``qualified,'' by defining certain minimum qualification standards for 
loan originators.\27\ The Bureau believed that those standards provided 
important consumer protections without imposing significant burdens on 
loan originator organizations.\28\ When the Bureau adopted Sec.  
1026.36(f)(3), the category of loan originators with temporary 
authority under the SAFE Act did not exist. Instead, the Bureau's main 
focus was on addressing the qualifications of employees of depository 
institutions, who are not subject to loan originator licensing under 
the SAFE Act at any point during their employment at those 
institutions.\29\ Under the scheme the Bureau adopted in Regulation Z, 
an individual loan originator's screening and training was either 
completed by the State (as part of reviewing an

[[Page 63794]]

application for a license) or by the loan originator organization 
employing the individual loan originator (to comply with Sec.  
1026.36(f)(3)). Under that scheme, both the State and the loan 
originator organization did not have to complete screening and 
training. If Sec.  1026.36(f)(3) were interpreted to apply to a loan 
originator organization that employs a loan originator with temporary 
authority, both the State (as part of reviewing the loan originator's 
application for a license) and the loan originator organization (to 
comply with Sec.  1026.36(f)(3)) would have to obtain the required 
criminal background and credit history reports and make the required 
criminal, financial responsibility, and character and fitness findings 
at the same time on the same individual. Similarly, both the State and 
the loan originator organization would have responsibilities related to 
the loan originator's training. This duplication of efforts would be 
inconsistent with the Bureau's purpose in issuing Sec.  1026.36(f)(3), 
because such duplication would not result in additional consumer 
protections that could justify these new burdens on loan originator 
organizations.
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    \27\ 78 FR at 11378; 15 U.S.C. 1639b(b)(1).
    \28\ 78 FR at 11378.
    \29\ 78 FR at 11378.
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    For these reasons, the Bureau concludes that the individual loan 
originators described in Sec.  1026.36(f)(3) do not include the loan 
originators with temporary authority described in section 1518 of the 
SAFE Act, 12 U.S.C. 5117. Thus, if an individual loan originator 
employee has temporary authority to act as a loan originator in a 
State, the loan originator organization is not required to comply with 
the screening and training requirements in Sec.  1026.36(f)(3) to 
permit that employee to act as a loan originator in that State.
    Finally, the Bureau underscores that loan originator organizations 
continue to be subject to the obligation in Sec.  1026.36(f)(2) to 
ensure that any individual loan originator who works for them is 
licensed or registered to the extent required by the SAFE Act, its 
implementing regulations, or State SAFE Act implementing laws before 
permitting the individual to act as a loan originator on a consumer 
credit transaction secured by a dwelling. Thus, when satisfying the 
loan originator organization's obligations under Sec.  1026.36(f)(2), 
the loan originator organization must ensure that any individual loan 
originator that works for it is either registered or licensed as 
required by the SAFE Act or excluded from those requirements because 
the individual may act as a loan originator with temporary 
authority.\30\
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    \30\ The Bureau also reminds loan originator organizations that 
they continue to be subject to Sec.  1026.36(f)(1)'s obligation to 
comply with all applicable State law requirements for legal 
existence and foreign qualification.
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II. Effective Date

    Because this rule is solely interpretive, it is not subject to the 
30-day delayed effective date for substantive rules under section 
553(d) of the Administrative Procedure Act.\31\ Therefore, this rule is 
effective on November 24, 2019, the same date that the EGRRCPA 
amendments to the SAFE Act take effect.
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    \31\ 5 U.S.C. 553(d).
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III. Regulatory Requirements

    This rule articulates the Bureau's interpretation of Regulation Z. 
As an interpretive rule, it is exempt from the notice-and-comment 
rulemaking requirements of the Administrative Procedure Act.\32\ 
Because no notice of proposed rulemaking is required, the Regulatory 
Flexibility Act does not require an initial or final regulatory 
flexibility analysis.\33\
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    \32\ 5 U.S.C. 553(b).
    \33\ 5 U.S.C. 603(a), 604(a).
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    The Bureau has determined that this interpretive rule does not 
impose any new or revise any existing recordkeeping, reporting, or 
disclosure requirements on covered entities or members of the public 
that would be collections of information requiring approval by the 
Office of Management and Budget under the Paperwork Reduction Act.\34\
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    \34\ 44 U.S.C. 3501-3521.
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IV. Congressional Review Act

    Pursuant to the Congressional Review Act,\35\ the Bureau will 
submit a report containing this interpretive rule and other required 
information to the U.S. Senate, the U.S. House of Representatives, and 
the Comptroller General of the United States prior to the rule's 
published effective date. The Office of Information and Regulatory 
Affairs has designated this interpretive rule as not a ``major rule'' 
as defined by 5 U.S.C. 804(2).
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    \35\ 59 U.S.C. 801-808.

     Dated: November 12, 2019.
Kathleen L. Kraninger,
Director, Bureau of Consumer Financial Protection.
[FR Doc. 2019-24944 Filed 11-18-19; 8:45 am]
 BILLING CODE 4810-AM-P