Course description

Various regulatory requirements apply to employees at your organization, depending on if they are a Mortgage Loan Originator (MLO); a Loan Originator (LO); both; or neither.  Do you know what each employee is?  Do they?

Making a proper determination of what each employee actually does in their job is foundational to building a solid compliance management program.  In addition to SAFE Act requirements, Reg Z contains complex rules for employees involved in home lending including: qualification requirements, compensation restrictions, disallowed payments, and steering prohibitions.

The SAFE Act has been around for a while now, and with time, full understanding and insights dwindle.  Staff members change and processes evolve.  Why are you doing what you do?  Take a new look at the requirements to make sure “what you’ve always done” is still appropriate and accurate.

Reg Z’s requirements at 1026.36 have always been complex, and the passage of time has not made them any clearer.  Examiners continue to look at this area of compliance with a fine-toothed comb, and your policy and procedures need to consider new lending programs, referral promotions, evolving employment roles, and broker relationships.  Don’t be caught off guard.  

Don’t leave this matter solely in the hand of Human Resources, even if it is rooted in employment issues.  Does your HR department know the details of the SAFE Act and Reg Z?  Surely not.  That leaves you, the compliance professional, to develop and implement a rock-solid plan to comply.  

This webinar will review SAFE Act and Reg Z requirements for MLOs and LOs, define and dissect key terms such as “Mortgage Loan Originator”, “Loan Originator” and “Compensation”, explore the impact of referral programs, and detail the requirements every LO must meet.   In addition to the webinar slides and manual, participants will receive a sample program to customize for their own institution, including a policy, employee survey, and sample training materials for in-house employee training.

Upon completion of this two-hour program participants will understand:

  • Compare and contrast MLOs and LOs
  • Requirements MLOs must follow;
  • Requirements LOs must follow, including all 1026.36 provisions 
  • How overly helpful employees can find themselves meeting the LO definition;
  • The Gotcha! game of referral and/or cross-selling programs;
  • Scenarios to illustrate real world examples;
  • Going beyond job titles;
  • Who owns MLO / LO oversight;
  • How to write (or update) an appropriate MLO / LO Program;
  • How to train all your employees, not just loan staff;
  • How to administer and track an employee survey;
  • Auditing the program;
  • Sample Policy;
  • Sample Employee Survey;
  • Sample Training Materials.


Join Rebekah as she goes from the big picture, down into all the various detailed aspects you need to know.  She has the real-life experience to share, in a relatable and engaging way.  Bring your questions!   


Rebekah Leonard

Rebekah is the owner of Elucidate LLC, a compliance training and consulting company. Elucidate means to "make clear, explain, throw light upon", and describes Rebekah's desire to illuminate the complexities of compliance with passion and fun. She's created and produced a TRID music video parody and several Compliance Breakout escape rooms, which she frequently provides at state banking compliance conferences. She is an accomplished speaker and regularly provides webinars through BOL and Compliance Resource. Rebekah is currently serving as the VP Director of Compliance for a $6 Billion community bank in Montana. She began her career in 1995 at a private lending company, but soon settled into banking, where she's covered nearly all of it - customer service and teller work, loan processing and review, and security and business continuity. She now oversees CRA, BSA and all aspects of compliance as a senior leader. She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams. Rebekah has a bachelor's degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006.

Course curriculum

  • 1


    • Access Webinar

  • 2


    • Materials

    • Slides

    • Policy - 1

    • Policy - 2

    • Sample - Power Point

    • Sample Survey