What the Role Looks Like
How a real estate agent becomes a bank originator.
The steps are the same whichever bank you join: hiring, registration, screening and training, then origination under the bank’s policies.
Why lender pay changes your status
An agent who only does real estate brokerage is not a loan originator under Regulation Z. That changes if the agent is compensated by a creditor or loan originator for a particular consumer credit transaction (12 CFR 1026.36(a)(1)). As a bank employee, you are paid by your employer for origination work you perform, under the registration and pay rules on this page.
What the bank checks
Before you originate, the bank obtains a criminal background check, a credit report and NMLS information about administrative, civil or criminal findings, then determines whether you meet felony-history and financial-responsibility, character and fitness standards. It must also provide periodic training on the federal and state law that applies to your work (12 CFR 1026.36(f)).
Your brokerage
Brokerages set their own policies on agents who originate. Some allow it with conditions; some prohibit it. State real estate law can also govern disclosure and compensation. Ask your managing broker first and get the answer in writing.
Acting as agent and originator on one deal
Texana Bank’s REMLO program is built for dual capacity: a REMLO may be paid on the real estate side and as a REMLO on the lending side of the same transaction. Program rules, state law and your brokerage still apply, and each same-deal file is reviewed before you act in both roles. See the companion guide on the same-deal question.
How Texana Bank handles it
Texana Bank, N.A. is a federally chartered national bank, and its REMLO role is a W-2 employee position. Hiring, NMLS registration, background checks, training and bank approval come before any origination, and a dedicated Texana team supports processing, underwriting submission, conditions, appraisal, disclosures and closing coordination. Minimum consideration requires both at least 6 buyer-side transactions and at least $1,800,000.00 in buyer-side sales volume over the trailing 12 months, independently verified. Meeting the minimums does not guarantee an offer; Texana also reviews fit, staffing and its hiring criteria. Compensation is for actual origination duties under an approved arrangement and is reviewed during the employment process.
If employment is not for you
You do not have to become an employee to work with Texana. An outside Realtor Partner relationship can be permanent. It gives your clients a lending team and gives you clear file updates, shared with your client’s permission, and it never involves payment for referrals.
