NARLO Loan Officer Investigations Process
The National Association of Responsible Loan Officers established a Code of Ethics as a guide to its members on how to deal with customers and each other; and how to comply with national, state and local regulations. Each member of the Association agrees to conduct business in keeping with this Code.
From time to time, the Association may receive contact from members and/or consumers regarding potential violations of this Code by a member, or we may become aware of alleged violations through reporting by the state mortgage broker regulators. To uphold our Code of Ethics and protect the reputation of the Association and its members, it is our duty to thoroughly investigate any such matters and determine whether the Code has been violated, and if so, what action should be taken in accordance with our Bylaws. All complaints must allege a violation of one or more segments of the Code of Ethics, either directly or indirectly.
Complaints Initiated by an Individual:
Any individual or individuals can make an ethics complaint about a member. Complainants do not need to be NARLO members.
Complaints must be received in writing and will be accepted into the official record of the proceeding. When submitting a complaint, the complainant should first show physical evidence that he/she attempted to come to a resolution with the loan officer member on his/her own (i.e., a letter). Once the complainant has sought resolution unsuccessfully on his/her own, he/she will need to forward a letter to NARLO headquarters containing the following:
1) A narrative statement describing the situation and a detailed listing of all relevant information and substantive issues of the complaint;
2) A copy of all forms, documentation and written correspondence related to the loan or the complaint; and
3) A recommendation as to what the ideal resolution to this complaint would be in the opinion of the complainant.
No action can be initiated until a signed, written complaint is received and all of the aforementioned documents are provided to the Association’s headquarters. Also, the Ethics Committee will not consider an ethics complaint if there is pending litigation. The Ethics Committee will table any ethics complaints during litigation and will consider them after all adjudication.
Any complainant may request that his/her identification be withheld. In this case, the complainant must provide his/her identification, items 1 through 3 listed above and justification as to why his/her identity should be withheld. The Ethics Committee has the sole discretion as to whether or not to withhold the identity of any complainant. In the event that anonymity is not granted by the committee, staff will contact the complainant to see if he/she wishes to continue to pursue the matter or withdraw the complaint.
Requests for Mediation by Loan Officer:
Any loan officer member may request that the Ethics Committee mediate a dispute with a customer.
Requests must be submitted in writing and will be accepted into the official record of the proceeding. When submitting a request for mediation, the member loan officer should first show physical evidence that he/she attempted to come to a resolution with the consumer on his/her own (i.e., a letter). Once the member loan officer has sought resolution unsuccessfully on his/her own, he/she will need to forward a letter to NARLO headquarters containing the following:
1) A narrative statement describing the situation and a detailed listing of all relevant information and substantive issues of the situation;
2) A copy of all forms, documentation and written correspondence related to the loan or the situation; and
3) A description of what the loan officer member believes is a reasonable offer to bring resolution to the situation.
No action can be initiated until a signed, written request for mediation is received and all of the aforementioned documents are provided to the Association’s headquarters. Also, the Ethics Committee will not consider any request for mediation if there is pending litigation. The Ethics Committee will table any requests for mediation during litigation and will consider them after all adjudication.