NE State Law Assignment 2 of 2

Case Study

Read the Below Case Study and Answer the 4 Following Multiple Choice Questions

Steve is a licensed MLO who helped a borrower named Vickie obtain a residential mortgage loan nine months ago. But now, seeing that interest rates have dropped significantly, Steve contacts Vickie about possibly refinancing her mortgage.

After two weeks of phone tag, in which Steve lets Vickie know that the rates could swing back up, she finally decides to come in and talk about a refinance.

Sure enough, by the time Vickie gets in to Steve’s office, the rates aren’t quite as good as they were when he originally contacted her. Even so, after running the numbers, Steve finds that Vickie will still save $85 per month on her mortgage payment with the refinance! So, Vickie applies to refinance her mortgage and is approved, while Steve makes a little money in the fees and charges on the loan.  

As you can see, Steve is very hands-on with and helpful to his clients. In fact, he wants to be a one-stop shop for them. With this in mind, Steve got has gone through training and is now a licensed MLO and a licensed real estate agent.

Steve takes immense pride in being as helpful as possible to his “full service clients” (those who use him for real estate and origination services). In fact, to make it more convenient for these full service clients, Steve has decided to keep their complete files together – with both original disclosures and documents from both the real estate and origination sides – at his MLO office. Just to cover all of his bases, Steve has worked up a disclosure outlining this practice of keeping the full service clients’ real estate and origination files together.
Bev, one of the owners of S & L Associates, tasks Steve with coming up with some ads to promote new loan products.

Steve recruits his co-worker Fred to brainstorm some concepts for ads. Since they are starting this project in late September, their main ad revolves around Halloween. It has a banner across the top that says, “Don’t be afraid of our sweet deals!” Okay, so it’s not the greatest advertisement ever created, but Steve and Fred are proud of it.

With the big creative hurdle out of the way, Steve delegates the job of filling in the standard information to Fred. The rest of the flyer is pretty standard stuff: Fred and Steve’s names and contact information, interest rate quote, repayment term of the loan in years, APR, company address, and S & L’s unique identifier. Fred even adds “Established in Nebraska in 1987” right under the S & L Associates logo as a final touch – just to give potential clients confidence that the company has longevity in the community.

Meanwhile, spurred on by his burst of ad-making creativity, Steve decides to design some new business cards for himself. He uses the S & L logo as a faded watermark across the front of the card, with his name and the office address, phone number, and website address front and center.

Fred brings his finished ad flyer to Steve for approval. Steve looks it over and decides it looks great. They e-mail an electronic copy to the rest of the office so that other MLOs can fill in their names and info and use the flyers to increase revenue.

Meanwhile, the director comes for his second examination of Steve’s activities in the last year and a half. The director’s office notifies Steve that there has been a complaint against him and that his records should be available for investigation immediately. Steve questions whether this investigation is fair, but he complies.

While he does have a flash drive at home with electronic versions of records, he decides not to bring it in because most of the records have corresponding copies in the office. 
The complaint against Steve actually comes from Vickie. After looking over her refinance paperwork, Vickie believes that Steve actually did a bait and switch on her final refinance rate. Even though she did save $85 per month on the payment, she feels that Steve could have gotten her a better deal.

Now, there are a few questions we should ask here:

1.     Which of the following violations did Steve commit in doing Vickie’s refinance?
A.     Steve contacted Vickie too soon to refinance her loan.
B.     Steve collected fees on the refinance loan.
C.     Steve’s solicitation efforts we illegal. 

2.     Look back over the information that Fred included in the flyer. Did he forget anything?
A.     Yes. Fred forgot to include information about whether the loan had a fixed or adjustable interest rate.
B.     No. For once, Fred actually did a thorough job in filling in the advertisement information.
C.     Yes. Fred forgot to include his and Steve’s unique identifiers. 
D.     Not really, but Fred should have included the repayment term for the loan in both years and months per the Nebraska State Law.

3.     What about Steve’s business card? Did it comply with Nebraska State Law?
A.     Yes. He put all of the pertinent contact information on it that a potential client would need. Otherwise, S & L would not have adopted it as a company-wide design.
B.     No. Steve should have included S & L’s unique identifier on the card.
C.     No. Steve should have included his own unique identifier.
D.     Both B and C.  

4.     Is Steve’s full service approach for his clients legal?
A.     Yes, because he discloses to these clients that he uses a combination real estate and mortgage loan filing system to retain their records.
B.     No, because he did not provide written disclosure to his clients that he was engaging in both real estate and MLO services.
C.     Possibly, as long as Steve’s disclosure mirrors the one outlined in the law. If not, the filing system might not be legal.

D.     Yes, Steve’s approach is legal. The filing disclosure is just a courtesy to his clients.



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