Compliance Blog

Posted by Anthony Demangone

Yesterday, the federal bank and credit union agencies announced the opening of the SAFE Act MLO registration system. 

Following expiration of the 180-day initial registration period on July 29, 2011, any employee of an agency-regulated institution who is subject to the registration requirements will be prohibited from originating residential mortgage loans without first meeting these requirements. The rules include an exception for mortgage loan originators that originated five or fewer mortgage loans during the previous 12 months and who have never been registered; they would not be required to complete the federal registration process.

So, here's a possible battle plan for compliance.

1. First, you need to understand if the rule applies to you, and if it does, who you plan to register as MLOs at your credit union. A good place to start is the NCUA SAFE Act webpage.   From there, you can read the regulation, and view the all-important Appendix A.  That appendix goes into examples of who is and who is not an MLO.  Also, read the NCUA FAQ document, which is also available form the NCUA SAFE Act webpage.  
2. Once you understand who will be registered, visit the registry website.   At the top of the page, you'll see a number of resources - including 2 "getting started" pages, and one training link. This resource page is also a gem of resources. Specifically, this grouping of "quick guides" is enough to make a compliance officer cry. (Like this one on getting fingerprinted.) These guys really have organized a ton of information for you. 
3. To top it off, they provide a number to a call center that is staffed with registry experts. The number: (240) 386-4444.  I tested it out.  A friendly fellow answered after one ring.  He confirmed the fact that he and his colleagues are there to help your registry-related questions.  (But they won't say who at your credit union will need to be registered.  Rather, they'll help you get those folks registered.)

I'll just pass on one tip.  That July 29th deadline might seem like a long way off in the distance. The folks who run the registry say to get started as soon as possible.  They also run the various state licensing systems, so they've managed this process a number of times.  And at the end of each deadline, they said that there were a small number of folks who waited too long and missed their respective deadline.  Don't be those folks.