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#1221403 - 07/23/09 05:27 PM
Re: SAFE Act licensing requirements
DD Regs
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Gold Star
Joined: Nov 2008
Posts: 498
Texas
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Yeah, but for Loan Officers to register in Texas they must have: (In addition to experience requirement, answer questions about personal history, fingerprinted, take and pass a pre-license test, background check and I'm only on page 3 of the 23 page application package)  60 hours of Core classroom training, including 4 hours of Ethics, offered by an SML-approved provider, taken within the last two years
OR
18 or more months of loan origination experience
AND 30 hours of Core classroom training, including 2 hours of Ethics, offered by an SML-approved provider taken within the last two years;
OR
Holds active Texas license as:
Real Estate Broker or Attorney or General Lines Agent (Life, Accident, Health, & HMO; or Property & Casualty); Limited Lines Agent (Multiple Lines); or Managing General Agent AND 30 hours of Core classroom training, including 2 hours of Ethics, offered by an SML-approved provider taken within the last two years;Is that Wal-Mart greeter job still open??
_________________________
Nothing ruins a Friday like realizing it is only Thursday
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#1221829 - 07/24/09 12:49 PM
Re: SAFE Act licensing requirements
Retired DQ
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Member
Joined: Jun 2009
Posts: 78
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The following information is from 7/20/09 Compliance Source from ABA
ABA has received multiple calls and e-mails regarding the S.A.F.E. Mortgage Licensing Act of 2008 Act and a supposed mandatory registration date of December 31, 2009 for loan originators employed by banks. This is not the case. Although the statute requires the registration of loan originators employed by banks, the regulation outlining the mechanism to accomplish this has not yet been established and no compliance date has been set. However, if you operate a state licensed mortgage broker or non-bank lender, then the appropriate employees of such an entity will need to be licensed according to the time-table and standards implemented by the state in question.
The relevant joint Notice of Proposed Rulemaking covering bank employed mortgage originators was published on June 9, 2009. Because of the complex technical issues involved in creating the registry, the proposed rule provides for a delay in implementation of the registration requirements until 180 days after the Registry becomes operational and available for initial federal registrations. To date, the final rule has not been issued and the Registry is not operational. In addition, ABA submitted its comment letter on July 9, 2009, and in that letter ABA urged the agencies to extend the implementation period to a minimum of 9 months, if not longer, once the registration system is operational, to allow banks time to adjust and adapt systems and procedures.
BOL Learning Connect sent out an email last week saying it is mandatory as of the end of the year. Which one is correct????
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#1222717 - 07/27/09 01:08 PM
Re: SAFE Act licensing requirements
BFaith
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Member
Joined: Jun 2009
Posts: 78
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The following information is from 7/20/09 Compliance Source from ABA
ABA has received multiple calls and e-mails regarding the S.A.F.E. Mortgage Licensing Act of 2008 Act and a supposed mandatory registration date of December 31, 2009 for loan originators employed by banks. This is not the case. Although the statute requires the registration of loan originators employed by banks, the regulation outlining the mechanism to accomplish this has not yet been established and no compliance date has been set. However, if you operate a state licensed mortgage broker or non-bank lender, then the appropriate employees of such an entity will need to be licensed according to the time-table and standards implemented by the state in question.
The relevant joint Notice of Proposed Rulemaking covering bank employed mortgage originators was published on June 9, 2009. Because of the complex technical issues involved in creating the registry, the proposed rule provides for a delay in implementation of the registration requirements until 180 days after the Registry becomes operational and available for initial federal registrations. To date, the final rule has not been issued and the Registry is not operational. In addition, ABA submitted its comment letter on July 9, 2009, and in that letter ABA urged the agencies to extend the implementation period to a minimum of 9 months, if not longer, once the registration system is operational, to allow banks time to adjust and adapt systems and procedures.
bump
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#1224629 - 07/30/09 01:42 PM
Re: SAFE Act licensing requirements
BFaith
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100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
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From what i am reading in the BOL Learning connect - it states this is covereage of the "proposed" rules.
My understanding the deadline for regulatory agencies to make a decision was July 29, 2009.
See below (taken from summary of BOL learning connect):
Will all of your bank's mortgage loan originators be licensed or registered by 12/31/2009? The Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE), proposed federal regulations and a host of state legislation and rules include licensing and registration mandates, and your staff isn't exempt. Will there be time enough for any background checks, training hours and testing that have to be completed? Banks with unlicensed or unregistered originators after year-end risk cease and desist orders and monetary penalties. Get the details on the new requirements and their effect on your mortgage lending program in this critically important webinar.
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#1224680 - 07/30/09 02:14 PM
Re: SAFE Act licensing requirements
Tryin-2-Comply
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Platinum Poster
Joined: Sep 2007
Posts: 937
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Ok! Let's say bank MLO's have to register with a federal agency. Who? and How? is this accomplished, if the agency has neither set-up the registry process nor is prepared for the onslaught of hundreds if not thousands of registrants. How will this be accomplished by December? I'm game if you can provide the road map to get us there.
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#1224692 - 07/30/09 02:19 PM
Re: SAFE Act licensing requirements
Tryin-2-Comply
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Member
Joined: Jun 2009
Posts: 78
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From what i am reading in the BOL Learning connect - it states this is covereage of the "proposed" rules.
My understanding the deadline for regulatory agencies to make a decision was July 29, 2009.
See below (taken from summary of BOL learning connect):
Will all of your bank's mortgage loan originators be licensed or registered by 12/31/2009? The Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE), proposed federal regulations and a host of state legislation and rules include licensing and registration mandates, and your staff isn't exempt. Will there be time enough for any background checks, training hours and testing that have to be completed? Banks with unlicensed or unregistered originators after year-end risk cease and desist orders and monetary penalties. Get the details on the new requirements and their effect on your mortgage lending program in this critically important webinar.
If you read Deekles post that I quoted above, the ABA is saying that registration is NOT required by 12/31/09; however the BOL Learning Connect email I got is saying that registration IS required by 12/31/09. Which is it??
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#1224698 - 07/30/09 02:24 PM
Re: SAFE Act licensing requirements
BFaith
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Power Poster
Joined: Mar 2004
Posts: 2,505
Up North
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From what i am reading in the BOL Learning connect - it states this is covereage of the "proposed" rules.
My understanding the deadline for regulatory agencies to make a decision was July 29, 2009.
See below (taken from summary of BOL learning connect):
Will all of your bank's mortgage loan originators be licensed or registered by 12/31/2009? The Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE), proposed federal regulations and a host of state legislation and rules include licensing and registration mandates, and your staff isn't exempt. Will there be time enough for any background checks, training hours and testing that have to be completed? Banks with unlicensed or unregistered originators after year-end risk cease and desist orders and monetary penalties. Get the details on the new requirements and their effect on your mortgage lending program in this critically important webinar.
If you read Deekles post that I quoted above, the ABA is saying that registration is NOT required by 12/31/09; however the BOL Learning Connect email I got is saying that registration IS required by 12/31/09. Which is it?? I am going with what the ABA and OCC are saying...effective date sometime in 2010. It would be nice however if BOL did address the email sent as it did send a couple people at my bank into a tailspin.
_________________________
Sometimes you have to burn a few bridges to keep the crazies from following you.
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#1224717 - 07/30/09 02:43 PM
Re: SAFE Act licensing requirements
RR Sarah
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Diamond Poster
Joined: Oct 2002
Posts: 1,027
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The BOL webinar ad talks about 20+ hours of education. I don't see anything in the proposed rules about required education. Where does that come into play?
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#1224736 - 07/30/09 02:49 PM
Re: SAFE Act licensing requirements
HR Banker
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Platinum Poster
Joined: Sep 2007
Posts: 937
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Maybe a visit to this site might help: http://www.csbs.org/AM/Template.cfm?Section=SAFE_Act SAFE was part of HERA and is cited as Title V of HERA. There are two distinct parts: Licensing and Registration. Licensing=State non-bank MLO's Registering= Bank employees (MLO's) of FI's That's my reading of Title V. Visit the cite. The CSBS thru the NMLS&R will keep up with the licensing and registration processes. But, to date I not sure of anything this admin does.
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#1225003 - 07/30/09 05:34 PM
Re: SAFE Act licensing requirements
Mrs. Rizzo
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Platinum Poster
Joined: Aug 2005
Posts: 914
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The site says:
On May 29, 2009, the Federal banking agencies issued a joint notice of proposed rulemaking concerning implementation of federal registration requirements of the Secure and Fair Enforcement for Mortgage Licensing Act of 2008.
Individuals and institutions covered by the proposed rule should not establish a record on NMLS at this point. Such individuals and institutions will be directed how to proceed after the Federal banking agencies promulgate a final rule.
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#1225107 - 07/30/09 06:31 PM
Re: SAFE Act licensing requirements
RR Sarah
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10K Club
Joined: Nov 2002
Posts: 20,656
The Swamp
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From what i am reading in the BOL Learning connect - it states this is covereage of the "proposed" rules.
My understanding the deadline for regulatory agencies to make a decision was July 29, 2009.
See below (taken from summary of BOL learning connect):
Will all of your bank's mortgage loan originators be licensed or registered by 12/31/2009? The Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE), proposed federal regulations and a host of state legislation and rules include licensing and registration mandates, and your staff isn't exempt. Will there be time enough for any background checks, training hours and testing that have to be completed? Banks with unlicensed or unregistered originators after year-end risk cease and desist orders and monetary penalties. Get the details on the new requirements and their effect on your mortgage lending program in this critically important webinar.
If you read Deekles post that I quoted above, the ABA is saying that registration is NOT required by 12/31/09; however the BOL Learning Connect email I got is saying that registration IS required by 12/31/09. Which is it?? I am going with what the ABA and OCC are saying...effective date sometime in 2010. It would be nice however if BOL did address the email sent as it did send a couple people at my bank into a tailspin. I agree, Sarah...it made me go into "what have I missed" mode...I thought I'd missed a final ruling!
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My opinion only. Not legal advice.
Say you'll haunt me - Stone Sour
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#1225233 - 07/30/09 07:32 PM
Re: SAFE Act licensing requirements
RR Joker
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Power Poster
Joined: Mar 2004
Posts: 2,505
Up North
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From what i am reading in the BOL Learning connect - it states this is covereage of the "proposed" rules.
My understanding the deadline for regulatory agencies to make a decision was July 29, 2009.
See below (taken from summary of BOL learning connect):
Will all of your bank's mortgage loan originators be licensed or registered by 12/31/2009? The Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE), proposed federal regulations and a host of state legislation and rules include licensing and registration mandates, and your staff isn't exempt. Will there be time enough for any background checks, training hours and testing that have to be completed? Banks with unlicensed or unregistered originators after year-end risk cease and desist orders and monetary penalties. Get the details on the new requirements and their effect on your mortgage lending program in this critically important webinar.
If you read Deekles post that I quoted above, the ABA is saying that registration is NOT required by 12/31/09; however the BOL Learning Connect email I got is saying that registration IS required by 12/31/09. Which is it?? I am going with what the ABA and OCC are saying...effective date sometime in 2010. It would be nice however if BOL did address the email sent as it did send a couple people at my bank into a tailspin. I agree, Sarah...it made me go into "what have I missed" mode...I thought I'd missed a final ruling! I know! I felt a little foolish because I thought I had let something slip past me and trust me, I don't like when that happens! 
_________________________
Sometimes you have to burn a few bridges to keep the crazies from following you.
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#1225243 - 07/30/09 07:42 PM
Re: SAFE Act licensing requirements
Mrs. Rizzo
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Diamond Poster
Joined: May 2005
Posts: 1,813
Giant side of TX
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That sounds correct to me . . . 1. Some state laws already require lenders to register, Thus the CSBS is the entity that has the existing Registry. 2. Now the Federal Law requires lenders to register - if you as a lender have already registered because state law requires it, you don't need to register again because the CSBS Registry will become the national registry.
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My opinions are just that, and might be worth what you paid for them.
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#1225276 - 07/30/09 07:59 PM
Re: SAFE Act licensing requirements
ktac MITCH
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100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
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I didn't say it was alredy a requirement - i said the agencies had until the 29th to approve proposed rules - and i've not seen or heard where they have done so....so, in my opinion this is still out there for a later date.
I was really only commenting that the BOL learning connect session was on "proposed" rules.
I agree - BOL needs to revise, adjust or address the training.
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