Built for dual capacity. Reviewed on every file.
Two federal programs speak to multiple roles directly. FHA’s Mortgagee Letter 2022-22 bars participants who have a direct impact on the mortgage approval decision, which it lists as underwriters, appraisers, inspectors and engineers, from having multiple roles or sources of compensation in a single FHA-insured transaction. Other participants may have multiple roles and sources of compensation for services actually performed and permitted by HUD, provided the transaction complies with all applicable federal, state and local laws.
USDA’s guaranteed loan handbook (HB-1-3555, Chapter 4, revised 08/05/2025) bars individuals with a direct impact on the mortgage transaction from holding multiple roles or having multiple sources of income in a single Rural Development transaction. Its examples, underwriters, appraisers, inspectors and engineers, end in “etc.”, so the list is open. It allows multiple roles for individuals without a direct impact on the approval decision. The handbook does not say where a loan originator falls, so the bank decides on each USDA file.
Texana Bank’s REMLO program is designed around dual capacity. A Texana REMLO may act as the agent and the loan originator on the same transaction and be paid for the work in each role, and Texana designs REMLO terms and compensation to comply with federal and state law. Each file is still checked against its loan program, the state, the REMLO’s brokerage and Regulation Z’s loan originator compensation rules before the REMLO acts in both roles.