OK MLO cheat sheet
OK MLO · Keep the key ideas within reach.
Federal Mortgage Laws and Regulations
RESPA Section 8 prohibits fees, kickbacks, or things of value for referrals of settlement-service business; penalties include treble damages and fines up to $10,000 per violation.
RESPA requires a Loan Estimate within 3 business days of application and a Closing Disclosure at least 3 business days before consummation; a valid changed circumstance permits a revised LE.
TILA/Regulation Z: the finance charge and APR must be disclosed; the right of rescission gives 3 business days to cancel a refinance or home-equity loan secured by a principal dwelling.
Ability-to-Repay/Qualified Mortgage (Regulation Z): covered loans require verification of eight underwriting factors; general QM uses a 43% debt-to-income benchmark plus product-feature limits.
ECOA/Regulation B prohibits discrimination based on race, color, religion, national origin, sex, marital status, age, or receipt of public assistance; adverse-action notice is due within 30 days.
HMDA (Regulation C) requires covered lenders to collect and report loan-level data, including ethnicity, race, sex, and pricing, for reportable applications.
Flood Disaster Protection Act: flood insurance is required for improved structures in Special Flood Hazard Areas on federally related loans, with notice and escrow rules.
SAFE Act (Regulation H) requires MLO licensing and registration, pre-licensing education, testing, and annual continuing education; the NMLS maintains the registry.
Fair Housing Act prohibits discrimination in sale, rental, and financing based on race, color, religion, sex, disability, familial status, or national origin.
General Mortgage Knowledge
Loan-to-value (LTV) = loan amount ÷ property value (or purchase price, whichever is lower); combined LTV (CLTV) adds all liens secured by the property.
Front-end ratio = housing payment (PITI) ÷ gross monthly income; back-end ratio = total monthly obligations ÷ gross monthly income.
Fixed-rate mortgages have constant principal and interest; adjustable-rate mortgages (ARMs) have an initial fixed period, then adjust by index plus margin, subject to periodic and lifetime caps.
Conventional loans are not government-insured; FHA loans are insured by HUD, VA loans are guaranteed by the VA, and USDA loans are backed by Rural Development.
Escrow/impound accounts collect monthly portions of taxes and insurance; RESPA limits the cushion to one-sixth of annual disbursements.
Points are prepaid interest: one point equals 1% of the loan amount; discount points lower the rate, while origination points are lender fees.
Private mortgage insurance (PMI) is generally required above 80% LTV on conventional loans and terminates at 78% LTV based on the original amortization schedule.
Amortization: early payments are mostly interest; the monthly P&I payment is fixed on a fully amortizing loan, and a balloon loan has a final lump-sum payment.
Mortgage Loan Origination Activities
The application stage collects the six TRID triggering items: borrower name, income, SSN, property address, estimated value, and loan amount.
Verification documents include pay stubs, W-2s, tax returns, bank statements, and a credit report; discrepancies must be documented and resolved.
The Loan Estimate must be delivered or placed in the mail within 3 business days of application; the borrower may shop for settlement services.
The Closing Disclosure must be received by the borrower at least 3 business days before consummation; a revised CD restarts the waiting period for certain changes.
Adverse action: a notice must be provided within 30 days of a completed application when credit is denied or the file is withdrawn; the notice states reasons or the right to request them.
Rate lock agreements must state the rate, lock period, and any fees; a float-down option must be disclosed in writing.
Appraisal requirements: the lender must provide a copy of the appraisal promptly and no later than 3 days before closing; the borrower may waive the timing.
The MLO must complete a full, accurate application, disclose all fees, and maintain records; the NMLS ID must appear on loan documents and advertisements.
Ethics
Fiduciary duty: place the borrower's interests above compensation; disclose conflicts of interest in writing.
Prohibited conduct includes fraud, misrepresentation, and steering borrowers to loans based on the MLO's compensation rather than the borrower's qualifications.
Confidentiality: nonpublic personal information may not be shared except as permitted by the Gramm-Leach-Bliley Act privacy rules.
Fair lending: do not vary terms, pricing, or service based on protected characteristics; disparate treatment and disparate impact are both prohibited.
Advertising must be truthful and not misleading; include the NMLS ID and required disclosures, and never guarantee approval or a specific rate.
Anti-money laundering (BSA/AML): report suspicious activity and file a Suspicious Activity Report (SAR); do not tip off the customer.
Red flags of fraud include inflated appraisals, straw buyers, undisclosed second liens, and income that does not match the stated occupation.
Oklahoma State-Specific Laws and Regulations
The Oklahoma Secure and Fair Enforcement for Mortgage Licensing Act (OSFEMLA) licenses MLOs through the Oklahoma Department of Consumer Credit; the NMLS is the system of record.
Oklahoma MLO pre-licensing education is 20 hours, including 3 hours of federal law, 3 hours of ethics, and 2 hours of nontraditional mortgage products; the SAFE test is required.
Annual continuing education is 8 hours, including 3 hours of federal law, 2 hours of ethics, and 2 hours of nontraditional mortgage products.
License renewal is annual; the license expires December 31, and renewal must be completed through the NMLS before that date.
Oklahoma prohibits unlicensed mortgage origination activity and imposes civil and criminal penalties, including fines and license revocation.
Oklahoma law requires disclosure of the MLO's NMLS unique identifier on loan documents and advertising.
Oklahoma's residential mortgage lending rules require written disclosures of fees and terms and prohibit unfair or deceptive practices under the Oklahoma Consumer Protection Act.
Oklahoma allows prepayment without penalty on residential first mortgages and limits late fees to 5% of the overdue payment.
Additional Oklahoma Licensing and Compliance Details
The Oklahoma Department of Consumer Credit examines licensed mortgage entities and may require books and records to be produced on request.
A mortgage broker license in Oklahoma requires a surety bond; the bond amount is set by rule and must remain in force while licensed.
Oklahoma licensees must notify the Department of Consumer Credit of changes in ownership, control, or address within the time set by rule.
Oklahoma law requires the MLO to provide a written loan origination agreement or disclosure before collecting fees from a borrower.
Records of mortgage loan transactions must be retained for the period required by Oklahoma rule and made available for examination.
Oklahoma prohibits making a mortgage loan without a license when licensing is required and prohibits aiding unlicensed activity.
The Oklahoma Real Estate Commission licenses real estate brokers; mortgage loan origination is regulated separately by the Department of Consumer Credit.
Oklahoma Enforcement and Consumer Protection
The Oklahoma Department of Consumer Credit may deny, suspend, or revoke a license for violations, fraud, or failure to meet licensing requirements.
Hearing rights: a licensee may request a hearing after an administrative action, and the Oklahoma Administrative Procedures Act governs the process.
Oklahoma's Consumer Protection Act prohibits deceptive trade practices in mortgage advertising and origination.
Oklahoma requires compliance with federal disclosure laws, including TILA, RESPA, and ECOA, as a condition of state licensure.
Oklahoma licensees must cooperate with examinations and investigations and produce records within the time specified by the Department.
Violations may result in civil penalties, restitution to borrowers, and criminal referral where fraud is involved.
Oklahoma Practice Rules for Mortgage Loan Originators
An Oklahoma MLO must be employed by a licensed mortgage entity; sponsorship is required before origination activity.
Oklahoma MLOs must complete pre-licensing education and pass the SAFE test before applying for a license through the NMLS.
Continuing education must be completed annually and reported through the NMLS; late completion may result in license inactivation.
Oklahoma requires the MLO to disclose the NMLS ID and the lender's identity on loan documents and solicitations.
Oklahoma prohibits dual employment or compensation arrangements that create undisclosed conflicts of interest.
Oklahoma licensees must maintain a physical office in the state or meet the Department's requirements for conducting business.
Oklahoma Compliance Review Checklist
Verify the MLO license status and sponsorship in the NMLS before originating any Oklahoma loan.
Confirm pre-licensing education (20 hours) and the SAFE test are complete before license application.
Confirm 8 hours of annual continuing education, including the required federal law, ethics, and nontraditional product hours.
Confirm the license renewal is filed before December 31 and the license remains active.
Confirm the NMLS ID appears on loan documents and advertising.
Confirm written fee disclosures and the loan origination agreement are provided before fees are collected.
Confirm records are retained and available for Department of Consumer Credit examination.
Oklahoma Penalties and Prohibited Acts
Originating without a license is prohibited and may result in civil penalties and criminal prosecution.
Fraud or misrepresentation in a mortgage application is grounds for license revocation and restitution.
Failure to complete continuing education may result in license inactivation and inability to originate.
Failure to disclose fees or the NMLS ID may result in administrative action by the Department of Consumer Credit.
Unfair or deceptive practices violate the Oklahoma Consumer Protection Act and may result in civil liability.