Have you ever heard the phrase "... complies with all applicable laws ...?" That vague string of words is included in every broker/originator agreement with their wholesale funding sources. What do you think it means? Being unaware of it or ignoring it, could be expensive. I've seen wholesalers, when they get squeezed, look 'downstream' to squeeze others.
If you're independent, then as a self employed individual, you have loads of compliance issues you must additionally follow (like you must have a 'written information security plan' - do you?), or you may be asked to buy back your loans! Believe me, when a loan get's bought back by the wholesaler - because their upstream funding source got burned, they look down hill at the broker of record, and all the way down to the originator to see who they can strong-arm into buying it back from them! Happens every day in this industry! Things like that won't happen to you next week, it will happen in a year or two, when you're doing better and have a little bit of money, more assets than you do now, etc. Even if you work for someone else, the Gramm-Leach-Bliley (GLB) Act requires you comply with it, and very specifically it effect what you do when you deal with applicants from your home/office - even as an employee.
Unless you live alone and nobody ever enters your home (housekeepers, 16 year old nephew, neighbors, etc) then you must: 1). lock rooms and file cabinets where paper records are kept; 2).using password-activated screensavers; 3).using strong passwords (at least eight characters long) etc. (the list is a long one).
Think about it. Do you "store paper records in a room, cabinet, or other container that is locked when unattended;
ensure that storage areas are protected against destruction or potential damage from physical hazards, like fire or floods; store electronic customer information on a secure server that is accessible only with a password - or has other security protections - and is kept in a physically-secure area; don't store sensitive customer data on a machine with an Internet connection; and maintain secure backup media and keep archived data secure, for example, by storing off-line or in a physically-secure area" -- if you don't, you're violating the GLB Act, and you could be subject to some unpleasant enforcement.
So you work on your computer a lot? Then you must: "Provide for secure data transmission (with clear instructions and simple security tools) when you collect or transmit customer information. Specifically: if you collect credit card information or other sensitive financial data, use a Secure Sockets Layer (SSL) or other secure connection so that the information is encrypted in transit; if you collect information directly from consumers, make secure transmission automatic. Caution consumers against transmitting sensitive data, like account numbers, via electronic mail; and if you must transmit sensitive data by electronic mail, ensure that such messages are password protected so that only authorized employees have access.
Here's where you can read all about it, all nice and neat for you to digest in one reading: http://www.ftc.gov/bcp/conline/pubs/buspubs/safeguards.htm and remember, when you violate just this one law, all the loans you work on at home are subject to be bought back.You may be stunned to learn what it is you don't even realize you don't know yet! And this law is one of the smaller ones you need to comply with, it ain't only all about selling and cashing big commission checks.
This isn't just any old commissioned sales job; there's scores of laws that regulate what you're allowed to do and what you should not. You don't get to play with the biggest single asset most families will ever have, their emotions and their future, when your training is only 20 minutes deep and you've been on the job a whole 10 months!
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