For state-licensed, non-depository lenders, the primary regulatory authority is the state regulator in the jurisdiction where the lender operates. Each state has its own agency or department responsible for overseeing licensing, compliance, and enforcement of mortgage laws for non-depository institutions.
* The NMLS (A) is the system used to manage licenses but is not a regulatory authority.
* The Federal Trade Commission (B) oversees federal consumer protection laws but is not the primary regulator for state-licensed lenders.
* The Conference of State Bank Supervisors (CSBS) (D) helps coordinate state regulation but does not directly regulate individual lenders.
References:
SAFE Act, 12 USC §5101
NMLS and State Regulator Guidelines

Under the TILA-RESPA Integrated Disclosure (TRID) rules, any significant change to the Annual Percentage Rate (APR) beyond the allowed tolerance before closing requires the lender to provide a revised Closing Disclosure (CD). If the APR increases by more than 0.125% for fixed-rate loans, the lender must re- disclose the CD and provide the borrower with at least three business days to review the updated terms before consummation (closing).
* In this case, the interest rate increase from 3.250% to 3.875% is a significant change that impacts the APR, triggering the need for re-disclosure and the mandatory three-business-day waiting period.
* The lender must postpone the closing until the new three-day waiting period passes to ensure compliance with TRID regulations.
References:
* TILA-RESPA Integrated Disclosure Rule (TRID), 12 CFR §1026.19(f)
* CFPB TRID Guidelines

Under HOEPA (Home Ownership and Equity Protection Act) rules for high-cost mortgages, a creditor may not refinance a high-cost mortgage into another high-cost mortgage within 12 months of the previous transaction unless the new loan is in the borrower's best interest. This is to prevent loan flipping and predatory lending.
"A creditor may not refinance a high-cost mortgage into another high-cost mortgage within one year unless the new loan is in the borrower's best interest."
- 12 CFR § 1026.34(a)(3)
Since the purpose here is a cash-out for a collector car (not generally a "best interest" purpose), the MLO should deny the loan unless a strong case can be made that it is in the borrower's best interest.
References:
CFPB, High-Cost Mortgages (HOEPA)
12 CFR § 1026.34(a)(3)

Section 8 of RESPA prohibits giving or accepting anything of value in exchange for referrals of settlement service business related to federally related mortgage loans. Renting office space at lower rates (or free) in exchange for referrals is specifically called out in RESPA guidance as an illegal kickback.
"Section 8(a) of RESPA prohibits giving or accepting any fee, kickback, or thing of value... for the referral of settlement service business. Examples of violations include... renting office space at above or below market rates based on the amount of business referred."
- 12 CFR § 1024.14; CFPB RESPA Section 8 Guidance
Hosting seminars, sponsoring uniforms, or donating to charity are generally permissible if not conditioned on referrals.
References:
CFPB, RESPA Section 8
SAFE MLO National Test Study Guide

Under Truth in Lending Act (TILA) Regulation Z, a finance charge is defined as the cost of consumer credit as a dollar amount, including any charges payable directly or indirectly by the consumer and imposed as a condition of or an incident to the extension of credit. Discount points are a form of prepaid interest paid at closing to lower the interest rate, and are always considered a finance charge.
"Finance charges include interest, points, and other costs payable by the consumer at closing, such as loan fees and certain mortgage broker fees. Charges such as appraisal fees, title insurance, and pest inspection fees are typically not finance charges if not required by the creditor."
- 12 CFR § 1026.4(a); TILA/Regulation Z Commentary
References:
CFPB, What is a finance charge?
12 CFR § 1026.4(a), Regulation Z