Compliance Blog

Sep 28, 2010

A SAFE Act Thought; Electronic BSA Manual Up and Running

Posted by Anthony Demangone

We've spoken to quite a few folks about the SAFE Act.  Some institutions are planning to register as few MLOs as possible, taking advantage of the de minimus exception, as well as reorganizing how they handle the mortgage origination process.  That's a business decision, so I won't second-guess you.  That being said, we've heard of credit unions and banks that are going to market the fact that their underwriters will be registered.  Along those lines, state mortgage companies seem to be planning to tout the fact that their folks are licensed.

With all of this in mind, here's a possible conversation you might have with your member.

Member: You've been so helpful answering questions about mortgages today.  What is your license or registration number? I've read that I can ask for this, right? 

MSR.  Yes, but I don't have a number.  I'm not required by the law to have one at this time. 

Member: So, you aren't licensed?

MSR: Well, I would only need to be registered as I work at a credit union.  But I'm not registered, as the regulation doesn't require it for people like me.

Member: Could I speak with someone who is licensed?

I think you get the point. It will be interesting to see how this ultimately shakes out.  Just keep in mind that people are going to market around the registration and licensing issue, so you should be prepared.

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When the FFIEC amended the BSA Manual this summer, they did not have an electronic version ready.  Rather, you had to download the entire 400+page manual and dig through it. No more!  An electronic version is now available.  Happy hunting.