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#1369418 - 04/05/10 06:21 PM SAFE Act Bank SA or Registry?
upstateNY Offline
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
I did listen to the BOL webex and thought it was very good. Unfortunatley I came away a little confused about who does what. The Q& A has helped some.

See if I have this part of the process correct?
1. LO signs in to Registry (when it becomes available) and provides basic information and fingerprints
2. "Signing in" provides permission for the Registry (FBI) to run it's background check.
3. LO receives unique ID number back.
4. Bank's SA provides additional info regarding employment and financial history to Registry.
5. Bank is also responsible for obtaining a credit report. Is this correct? AND, for
6. Running it's own background check? This is what has me confused.

Does the bank run both a credit report and background check?

Last edited by upstateNY; 04/05/10 06:32 PM.
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Lending Compliance
#1369479 - 04/05/10 08:02 PM Re: SAFE Act Bank SA or Registry? upstateNY
CompDat Offline
Platinum Poster
Joined: Dec 2005
Posts: 553
USA
I saw this post and I got confused myself. I work for a national bank. Correct me if I am wrong, but.... according to the FFIEC page: http://www.ffiec.gov/safeact.htm#finalized

The ombudsman is currently reviewing and no final rule has come out. We will also be given 180 days (6 months) notice. I am not implying that it is not important to keep this stuff up and ready to go, but nothing is final at this point.

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#1369792 - 04/06/10 04:07 PM Re: SAFE Act Bank SA or Registry? CompDat
upstateNY Offline
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
Originally Posted By: CompDat
I saw this post and I got confused myself. I work for a national bank. Correct me if I am wrong, but.... according to the FFIEC page: http://www.ffiec.gov/safeact.htm#finalized

The ombudsman is currently reviewing and no final rule has come out. We will also be given 180 days (6 months) notice. I am not implying that it is not important to keep this stuff up and ready to go, but nothing is final at this point.


You are correct. But we are starting now to identify "who" we will register and to develop procedures. We have several hundred LO to register.

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#1369921 - 04/06/10 06:15 PM Re: SAFE Act Bank SA or Registry? upstateNY
DD Regs Offline
Power Poster
DD Regs
Joined: Nov 2008
Posts: 4,132
Somewhere in the middle
ABA Newsbytes had a good article today. Hopefully the agencies will listen to ABAs advice on definition of MLOs.
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