RMLO License/SAFE ACT

[James Gravitt]

I was thinking about getting my license to become a loan originator. Its only 4 days worth of class time and it costs around $300.
With this I could also do loan originations for other people and charge a fee.

Do you hink this is a good idea and would it be a good move in the MH buying/selling?

[Karl V.]

Hi

Eric is right, and TX is one of the states that requires that originators be sponsored by a mortgage broker.

Oh, and you can't apply to be a mortgage broker unless you have years of experience in the mortgage business.

Yep, it's a private club and you can't just get in without drinking their kool-aid.

Also, because this is a relatively new and untested law, what transactions are exempt is still open to wide interpretation by those who enforce it. I've talked to closing attorneys that have refused to work on a deal because they are avoiding the issue until court cases clarify it.

The safe thing to do is to pay a licensed originator to do your work for you, if you can find one that will do it without screwing up the deal, and if you can get one at a fair price.

BTW, if there's anyone out there using a licensed MLO, what are you paying for their services?

Karl
[LINK REMOVED]

[Jay Hinrichs]

@Ken Rishel

  thanks Ken  apprcieate it

[Jay Hinrichs]

@Ken Rishel

  I see your specialty is MFH  and Chattels.. somewhat different than the current safe act issues unless they run parallel.. I could not get your newsletter link to work.

[Bill Gulley]

@Jay Hinrichs

and everyone; 

I have  never endorsed anyone on BP, not that my 3 pounds of influence would count for anything, but I just haven't as I feel my reputation would be "on the line" in doing so, there are "liabilities" that go along with endorsements.

But, I will say that I'm beyond impressed with  @Ken Rishel  and his organization. He has not been as active on BP as I'd like to see, but I'm sure that means he's busy. What he has posted I have found to be accurate and correct. I trust what he has to say concerning Dodd-Frank and related regulatory issues, after all compliance is his business. 

I see that Ken is on the/a "Dodd-Frank Task Force" not sure if that is a government type task force as is often formed between agencies and industry "experts" or if it is a private organization to study these regulatory matters. Either way, I have been in such groups and they usually will have concentrated activities that yield what I might call "inside information". He might touch on that. 

While I plan on brushing up on this area after the dust settles if anyone is serious about seller financing as a business operation I'd suggest you get with Ken. 

As to chattel financing, the collateral security is different than real estate and it's my understanding that there have been special provisions made for mobile home dealers, but all in all, I'd think that the underwriting and prudent lending aspects will be much the same, regardless of the classification of a consumer loan. 

As one with a regulatory mind set, if I were to examine an organization doing real estate loans and found that they were in compliance adapting a structure or operation used in the mobile home industry, still in line with the intent of the law, I certainly wouldn't be alarmed. Ken and I are in different lanes of traffic, but we are going the same direction.   

That might be more than 3 pounds worth, but I'd think getting on Ken's mailing list for his newsletter would be necessary reading for dealers or operators trying to do seller financing in this environment today.

There is a lot of bad information out there, there is somewhat of an art to interpreting financial rules, regulations and law and they are not written for public consumption, in fact, they aren't really written for the average attorney but for specialists in that arena. :) 

[Ken Rishel]

Originally posted by @Jay Hinrichs:

@Ken Rishel

  I see your specialty is MFH  and Chattels.. somewhat different than the current safe act issues unless they run parallel.. I could not get your newsletter link to work.

 The newsletter is emailed. I did not give a link, but rather, the email address of the lady that is in charge of subscriptions and editing the newsletter.

[Ken Rishel]

Originally posted by @Bill Gulley:

@Jay Hinrichs

and everyone; 

I have  never endorsed anyone on BP, not that my 3 pounds of influence would count for anything, but I just haven't as I feel my reputation would be "on the line" in doing so, there are "liabilities" that go along with endorsements.

But, I will say that I'm beyond impressed with  @Ken Rishel  and his organization. He has not been as active on BP as I'd like to see, but I'm sure that means he's busy. What he has posted I have found to be accurate and correct. I trust what he has to say concerning Dodd-Frank and related regulatory issues, after all compliance is his business. 

I see that Ken is on the/a "Dodd-Frank Task Force" not sure if that is a government type task force as is often formed between agencies and industry "experts" or if it is a private organization to study these regulatory matters. Either way, I have been in such groups and they usually will have concentrated activities that yield what I might call "inside information". He might touch on that. 

The task force referred to is one set up by an national industry trade group (Manufactured Housing Institute) that is comprised of who they view as leaders in manufactured home finance. Being a part of this task force, gives "special credentials" of a sort with government agencies, because they are more likely to listen and sometimes defer to a group with a lot of power behind them.

As to Bill's point, we do have regular access to people working for the CFPB and I have attended and participated in semi closed meetings in which the CFPB, DOJ, FTC, and other federal agencies meet with state regulators to discuss regulation and enforcement. One of the benefits of being this involved is being privy to their thinking and what they are planning for the future.

While I plan on brushing up on this area after the dust settles if anyone is serious about seller financing as a business operation I'd suggest you get with Ken. 

As to chattel financing, the collateral security is different than real estate and it's my understanding that there have been special provisions made for mobile home dealers, but all in all, I'd think that the underwriting and prudent lending aspects will be much the same, regardless of the classification of a consumer loan. 

There are things that are very different in chattel lending on a residence, but there are many that are now the same as real estate mortgage lending. Some differences are because the MHI Dodd-Frank Task Force was able to negotiate exemptions or different rules (like the interest caps for "rebuttable presumption" protection and methods of appraisal) and some that were left the way they were prior to the SAFE Act and the Dodd-Frank Act by a lack of action to include chattel into a rule or regulation. 

As one with a regulatory mind set, if I were to examine an organization doing real estate loans and found that they were in compliance adapting a structure or operation used in the mobile home industry, still in line with the intent of the law, I certainly wouldn't be alarmed. Ken and I are in different lanes of traffic, but we are going the same direction.   

That might be more than 3 pounds worth, but I'd think getting on Ken's mailing list for his newsletter would be necessary reading for dealers or operators trying to do seller financing in this environment today.

There is a lot of bad information out there, there is somewhat of an art to interpreting financial rules, regulations and law and they are not written for public consumption, in fact, they aren't really written for the average attorney but for specialists in that arena. :) 

[Jay Hinrichs]

@Ken Rishel

  cool thanks ,, would be great to get an accurate picture.. as you probably aware a lot of arm chair coaching goes on regarding these regs here on BP

@Bill Gulley

thanks Bill now if there was something like this for wholesaling we would have half the BP content put to bed LOL

[Bill Gulley]

Thanks @Ken Rishel, that's what I thought. I would have to reread the aspects of under served areas with safe haven assumptions as to how they are going to view rural areas, off the top of your head, I assume they will be guided by regional MSAs as to what is under served. (?)    Ken, you mentioned in one of your posts you were working on a rendition of 'deals on wheels", I'd like to run that by with you sometime.

We appreciate your feedback, Ken.  

Jay, LOL, yes, the wholesaling issues, that might come out of the ARELLO supporting regulatory reform on a national basis with state regulators. 

I'm aware of a book on seller financing by a qualified attorney out of NC I believe it is, I'll review that when it's out, but it is most likely state specific. I say "qualified" as the author was legal council with FDIC at one time being familiar with banking and compliance. :)

[Ken Rishel]

Originally posted by @Bill Gulley:

   Ken, you mentioned in one of your posts you were working on a rendition of 'deals on wheels", I'd like to run that by with you sometime.

We appreciate your feedback, Ken.  

Bill, I would be happy to discuss it, but it cannot be on Bigger Pockets as they might view it as self promotion. I can tell you that Jackie (Lonnie Skruggs' daughter) is holding a special teleconference on Tuesday evening, July 7th, to introduce this solution to hundreds of Lonnie Dealers.

In addition, there is a group: Lonnie Dealer Forum on Linkedin, that contains more information. (You would have to be on Linkedin and would have to ask to join the group to access the forum however.) 

[Bill Gulley]

Originally posted by @Ken Rishel:

Originally posted by @Bill Gulley:

   Ken, you mentioned in one of your posts you were working on a rendition of 'deals on wheels", I'd like to run that by with you sometime.

We appreciate your feedback, Ken.  

Bill, I would be happy to discuss it, but it cannot be on Bigger Pockets as they might view it as self promotion. I can tell you that Jackie (Lonnie Skruggs' daughter) is holding a special teleconference on Tuesday evening, July 7th, to introduce this solution to hundreds of Lonnie Dealers.

In addition, there is a group: Lonnie Dealer Forum on Linkedin, that contains more information. (You would have to be on Linkedin and would have to ask to join the group to access the forum however.) 

 Thought the book rights were sold to another writer who is a member on BP, at least she claimed she had them. But, this may be different.

I'll get with you, thanks again. And, no, I'm not on Linkedin, guess I can find someone who is. Do they know who I am? They may not let me join.....LOL :)

[Brian Gibbons]

@Bill Gulley

if they lock you out let me know and I will let you know what I see on linked in :)

[Derek B.]

Originally posted by @Bill Gulley:

I'm aware of a book on seller financing by a qualified attorney out of NC I believe it is, I'll review that when it's out, but it is most likely state specific. I say "qualified" as the author was legal council with FDIC at one time being familiar with banking and compliance. :)

Bill, would you share the book name or author? Sounds like it may not be out yet but I would like to look into it when it is out. 

[Bill Gulley]

Originally posted by @Derek B.:

Originally posted by @Bill Gulley:

I'm aware of a book on seller financing by a qualified attorney out of NC I believe it is, I'll review that when it's out, but it is most likely state specific. I say "qualified" as the author was legal council with FDIC at one time being familiar with banking and compliance. :)

Bill, would you share the book name or author? Sounds like it may not be out yet but I would like to look into it when it is out. 

 No problem, just PM me, I'm not sure about the state but I'll look it up for you. It's a little over $225 as I recall. :)

[Aaron B.]

Also interested in the NC-specifc book mentioned above.

[Philip Pring]

Does Anyone Know of an RMLO service in Texas? preferably in Austin. If so please let me know. 

[Ken Rishel]

Originally posted by @Jay Hinrichs:

@Ken Rishel

  I see your specialty is MFH  and Chattels.. somewhat different than the current safe act issues unless they run parallel.. I could not get your newsletter link to work.

 The newsletter link is to a email address to request a subscription. If your email is not set up to automatically pop up a email form, it doesn't work. If Bigger Pockets does not object; newsletter at rishel.net is the email address. Julie Anderson is in charge of the newsletter. She will need your name, your company name, and your physical address as well as telephone contact information for her records. This is, in part, to avoid any whiff of SPAM and to contact you if the emailed newsletters are not going through to try to fix any problems.

Interestingly, the July 2016 issue has an article that relates to the subject being discussed here.