In reading Section 1007.103(b) it appears it would be MLO's responsibility to update their employment status with the NMLS. We had a MLO leave the bank 6 months ago but NMLS Consumer Access still shows her as representing our Bank. Who is responsible for updating this information?

We have had employees leave who were registered with the NMLS and we have gone in and terminated their employment with us. They still show up on the registry but they do not represent anyone.

Ditto JWills comments.

Should that be part of the "exit interview" process? I say that, but unfortunately HR was not informed that this employee was leaving until after she had already left.

IMHO - It should be part of the exit process that is no less important than getting their keys back from them. Doesn't HR have a exit checklist???

And as part of a recent SAFE Act audit, we had to show when an employee left and when we terminated their employment on the NMLS.

JWills and Skittles are correct. You have to go into the registry and "un-tag" them as employees of your bank. After you have "un-taged" them, they will still show up in the registry, but not as a person representing your bank.

I agree rlcarey. I will be asking my HR person this every question.

If I may ask, and if need be, I can post an independent question on it; is there a requirement as to how far back a background check on an employee must go?

This has been an ongoing debate that we have not found an answer to...

thanks in advance

Well, a criminal background check always goes back to the day they started walking upright, so I'm not sure what you mean???

Your statement sort of answers my question; the debate going back and forth was the question if there was a "minimum" time period for a background check. My understanding was that an FBI report pretty much was all encompassing.

I am all for the rehabilitation of criminals, but if someone robbed a bank 20 years ago, I'm not sure I would want someone performing a minimum background check for the last 10 years. Financial checks would normally be limited to available information via a credit report.