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A national nonprofit housing counseling organization trains its counselors to help low-income borrowers understand mortgage products, review loan documents, and identify predatory loan terms. Some counselors also help borrowers select specific loan programs and contact lenders on borrowers' behalf. Which of the following counselors is most likely to need an MLO license?

Uniform State Test (UST) · 11% of the SAFE examhard

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Correct answer: A counselor who contacts multiple lenders on a specific borrower's behalf, compares loan offers, and advises the borrower on which loan product to select and on what terms

The SAFE Act's licensing requirement is activity-based. An individual who negotiates mortgage terms, assists a borrower in selecting a loan product, and contacts lenders on the borrower's behalf is performing activities that fall within the MLO definition — regardless of whether the individual works for a nonprofit. The counselor in "A counselor who provides referrals to licensed MLOs..." is functionally acting as a mortgage broker. A homebuyer education instructor (A) discussing general processes is not originating loans. A counselor reviewing post-closing documents (B) is performing educational support after origination is complete. A counselor making referrals without discussing specific loan products (D) is performing a referral function that does not require licensure under the SAFE Act.

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