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. Â 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. Â That's a business decision, so I won't second-guess you. Â That being said, we've heard of credit unions and banks that are going to market the fact that their underwriters will be registered. Â 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. Â What is your license or registration number? I've read that I can ask for this, right?Â
MSR. Â Yes, but I don't have a number. Â I'm not required by the law to have one at this time.Â
Member:Â So, you aren't licensed?
MSR:Â Well, I would only need to be registered as I work at a credit union. Â 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. Â 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.