S.A.F.E Act

Hello all,I am new to the audit dept and in the past we have done our S.A.F.E. Act testing as part of our Mortgage Audit.  We have now pulled it out as a separate audit.  We have call center/branch personnel that enter mortgage/home equity applications into a system that forwards the app information to the Lending department for decisioning.  Currently these employees do not have MLO numbers.  After reading the parts of the regulation I've included below I am led to believe they should be registered.  Any thoughts or advice?         Based on Appendix A to Part 1007 - Examples of Mortgage Loan Originator ActivitiesTaking an Application"(iii) Is inputting information into an online application or other automated system on behalf of the consumer"andOffering or negotiating terms of a loan include:"(i)Presenting a loan offer to a consumer for acceptance, either berbally or in writing, including, but not limited to, providing a disclosure of the loan terms after application under the Truth in Lending Act, .."