SAFE Act / State Transitional Licenses FAQ 2 – Does EGRRCPA impact the status of state transitional licenses under the SAFE Act?

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Q:  Does EGRRCPA impact the status of state transitional licenses under the SAFE Act?
 
 
A:  No. The EGRRCPA amendments to the SAFE Act will not affect the permissibility of transitional licensing under the SAFE Act and Regulation H, which was addressed in the Bureau’s Bulletin 2012-05. The EGRRCPA amendments do not impact the ability of a state to consider or rely on a prior state’s findings when considering a State-Licensed Loan Originator’s license application, as discussed in the Bureau’s 2012 bulletin.
 
The EGRRCPA amendments establish temporary authority, which provides a way for eligible loan originators who have applied for a new state loan originator license to act as a loan originator in the application state while the state considers the application.  
 
For more information on Loan Originators with Temporary Authority, see SAFE Act Types of Loan Originators Question 1 and State Transitional Licenses Question 1.  
 
Updated Sept. 25, 2019
 
 
 
The CFPB’s SAFE Act FAQs pertain to compliance with the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE Act) as of November 24, 2019, the effective date of the 2018 amendments to the statute.  Information may be found here:  https://www.consumerfinance.gov/policy-compliance/guidance/secure-fair-enforcement-for-mortgage-licensing-act/secure-and-fair-enforcement-mortgage-licensing-act-faqs/
 
Reviewing these questions and answers is not a substitute for reviewing the SAFE Act or the Bureau’s Regulation G or Regulation H. The statute and Regulations G and H are the definitive sources of information regarding the requirements. 
 
 
 

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