Q: Does EGRRCPA impact the status of state transitional licenses under the SAFE Act?
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.
Updated Sept. 25, 2019
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.