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Does the law that prohibits mortgage brokers from originating no income verification loans apply to a bank that is originating FHA No Credit Check Streamline Refinances? – IBA Compliance Connection

Does the law that prohibits mortgage brokers from originating no income verification loans apply to a bank that is originating FHA No Credit Check Streamline Refinances?

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The law you refer to, Section 5-6 of the Illinois Residential Mortgage License Act of 1987, includes an exemption for banks. 205 ILCS 635/1-3(a)205 ILCS 635/1-4(d). However, if you have subsidiaries that are not banks, you will have to determine whether the Act’s restrictions apply to them.