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Abstract: 

On November 24, 2019, Section 106 of the Economic Growth, Regulatory Relief and Consumer Protection Act went into effect, amending the federal Secure and Fair Enforcement for Mortgage Licensing Act (“SAFE” Act) to provide eligible federal registrants and state mortgage loan originators (“MLOs”) with temporary authority to operate (“TA”) in a state while their application for MLO licensure in that state is pending. TA went into effect by operation of law, whether or not states had made implementing changes to their corresponding statutes, and the Nationwide Multistate Licensing System & Registry (“NMLS”) was ready. Then a global pandemic came along. In this article, the author discusses issues arising for employers and MLOs in connection with TA-eligible MLO applications, as affected by the pandemic.

Keywords: Temporary Authority to Operate (“TA”); Mortgage Loan Originator License; Withholding Sponsorship

Affiliations:  1: Ballard Spahr, LLP.