Compliance Blog

Written by Steve Van Beek

On Tuesday evening, the Treasury Department announced a transition in the leadership for the Consumer Financial Protection Bureau.  Professor Warren will be returning to Harvard Law School this fall and Raj Date will be the new Special Advisor to the Secretary on the CFPB.  The transition takes effect on August 1, 2011.   

If that name sounds familiar, it is because Date is currently the Associate Director of Research, Markets & Regulations at the CFPB.  His name was also floated earlier as a potential nominee for the Director position (or in hindsight - perhaps the trial balloon was to see the reaction if Date replaced Warren?).       

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Just a friendly reminder that the SAFE Act registration for mortgage loan originators (MLOs) needs to be completed by tomorrow - Friday, July 29.  There is no flexibility built into NCUA' regulation on this issue.  If your MLOs are not registered, they cannot act as MLOs after July 29.  From 12 C.F.R. 761.103(a)(2):

"(2) Credit union requirement â€”(i) In general. A credit union that employs one or more individuals who act as a residential mortgage loan originator must require each employee who is a mortgage loan originator to register with the Registry, maintain this registration, and obtain a unique identifier in accordance with the requirements of this part.

(ii) Prohibition. A credit union must not permit an employee of the credit union who is subject to the registration requirements of this part to act as a mortgage loan originator for the credit union unless such employee is registered with the Registry pursuant to this part." 

Part 761 of NCUA's regulations, implementing the SAFE Act, is here.  NCUA's SAFE Act webpage is here.

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If you follow Major League Baseball, you probably heard about the 19 inning game played between the Pirates and Braves on Tuesday night.  The game ended with an.....interesting call at home plate.  

The game also brought back memories of my last high school baseball game - which also lasted 19 innings.  In our game, we used two pitchers for the entire 19 innings (the Pirates used 7 and the Braves used 8 last night).  I had the unique opportunity to be both the starting pitcher and the losing pitcher in our 19 inning game.  Long story short, the Michigan High School rules allow a pitcher to go out of a game but come back in to pitch.  I pitched 5 innings, played 10 innings at shortstop, and then pitched 4 more innings.

The pitcher who replaced me (and who I then replaced) - pitched ten innings without giving up a hit (innings 6-15).  That would have been a huge story had it been a normal game - but that fact was lost in the 19 inning marathon.  

Michigan High School rules also limit a pitcher to 10 innings.  I still wonder how many innings of no-hit ball our other pitcher would have thrown if he could have stayed in the game.  Also, we would probably have had a better chance of winning.