What about the title of the employee who originates residential mortgage loans?
Here are some titles we have found: Loan Officer, Loan Advisor, Senior Loan Advisor, Mortgage Banker, Branch Partner; Mortgage Expert Loan Consultant, Loan Planner, Financial Planner, Mortgage Consultant, Mortgage Advisor, Mortgage Planner, Branch Manager, Area Manager, Vice President, Production Assistant, Professional Mortgage Consultant, Loan Specialist,
You can also add: Senior; Registered; Licensed; and/or Certified to these titles.
We have also found: Business Development Guru, Mortgage Geek, Mortgage Samurai, Mortgage Guru, Certified Divorce Lending Professional; Director of First Impressions, Native American Lending Specialist, The Loan Arranger; Financial Mentor as well as Queen and King of Mortgages.
Sometimes there are letters or certifications added after the title: CMP or Five Star Professional.
All of these folks have identical credentials and perform the same function…they are licensed (registered) to originate residential mortgage loans.
The CFPB Examination Procedures, January 2014, Module 2 – Advertising and Marketing directs the Regulator to:
“8. Determine whether advertisements and promotional materials for mortgage loan products contain misleading representations that a lender or broker is acting in a fiduciary capacity or in the consumer’s best interest, if in fact, the lender or broker has no fiduciary duty.”
Titles do matter and can create the perception of fiduciary relationship where it does not exist or constitute a UDAAP violation subjecting the Company to reputation and regulatory risk.
To make sure your firm and your loan originators are compliant on email, in their sig lines, out on the web, and in social media ... contact our friends at AcuClix Social Media Compliance. The contact info for their TMC dedicated resource, Mike Wallace, can be found below.
Michael J. Wallace, Esq.