Compliance Memo C2021-03 Dual Capacity
This memo is in regards to those MLO’s that also have dual employment as a Real Estate Agent/Broker. The following states have a Dual Capacity or Conflict of Interest Disclosure which may be required to be sent to your borrower(s) if this situation applies.
This disclosure is available in Encompass, but requires specific data entry or printing requirements by state for specific loan perimeters.
These states include:
District of Columbia (DC)
If you have a loan in any of these states and dual capacity applies, please reach out to me directly to confirm if disclosure is required and instructions on how to obtain it. Note, this may only apply if you are both the MLO and Real Estate Agent.
If you have dual employment in another capacity other than real estate agent/broker and you are both on a particular loan, please reach out as there may be additional requirements needed.