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Are brokers who are exempt from the bond requirement permitted to take an applicant's credit card number and pass it on to the lender or appraisal management company without violation of section 4(1) of the MBLSLA?

Are brokers who are exempt from the bond requirement permitted to take an applicant's credit card number and pass it on to the lender or appraisal management company without violation of section 4(1) of the MBLSLA?

The taking of credit card information does not constitute receiving funds from a prospective borrower before the closing of the mortgage loan. Accordingly, the exempt broker (because they agree not to take fees from the applicants prior to closing) would not violate Section 4(1) of the MBLSLA by doing so.