No idea - we'll know when the registry is up and running. I feel like there is no use in trying to figure out the logistics of fingerprinting until then.

Don't you love how they come out with a rule without even having the systems capable of facilitating the rule ready????

If the Registry will work the same way for bank registration that it does now for non-bank MLO registration, the fingerprinting and CBCs will be done through the Registry. Currently non-bank MLOs must submit their fingerprints using an approved vendor with the Registry and request the CBC when they input their info. See this link (note---this is not ready for bank registration, only listed as an example of what to possibly expect):

http://mortgage.nationwidelicensingsystem.org/profreq/background/Pages/default.aspx

Dani,
I've been using the same page, that you linked above to try to use an an example to explain the process to our HR committee. I hate that I can't give them answers.

It looks like option one is to get the fingerprints on a card (ink) and doing so will cost around $10 more per registration.

Option two is the electronic route, via a vendor. I should call a vendor and see what they have to say.

I would advise that you wait until the Registry is available, or at least until they can tell us more about what must be done through the Registry. You don't want to contract with someone to get the fingerprints only to find that you won't be able to use them.

Just explain to HR that until we know more, the specifics of how, when , and where can't be determined. Just work on the bare bones policy...who will enter the info (HR or the employee), what kind of time frames to allow new hires to Register, what disciplinary action for adverse CBC findings, etc.

You can add the meat and potatoes later. Just concentrate on setting up the place setting right now.

Does anyone know if a credit report will be reviewed by the registry during the background check when registering Loan Officers? Seems like I have seen that somewhere, but can't locate it.

The bank is responsible for all of the reviews. The Registry is only the conduit for obtaining the information. I attended a webinar that indicated that the credit check would be pulled through the Registry as well as the background check. But the bank is the only one who actually reviews/analyzes teh information contained therein.

You might be thinking of the licensing requirements. I know for licensing LOs have to submit financial information - not totally sure if their credit report is reviewed by the licensing authority though.

Oh, I know that. I was thinking of calling a vendor and asking what they are currently doing on the licensing side. sorry for not being clear.

Oops, sorry QCL...

Don't be. It's all so confusing!
I'm presenting my policy tomorrow for approval...yippie.

Agreed. Are you willing to share into the library your draft of the SAFE Act policy and procedure? I am sure a lot could use the help. We are a big bank and have a lot of employees that will fit this description. Thanks

Does any one know who many characters the unique identifier will require? Is it just numeric? The rules just state that it would be in the format established by the Registry but not finding anything on the NMLS website that specifically states this.

Also I was reading some posts in this thread about which documents the identifier will be required on. The Dodd-Frank reform act provides in Title XIV that it will be provided on "all" loan documents.

‘‘(B) include on all loan documents any unique identifier of the mortgage originator provided by the Nationwide Mortgage Licensing System and Registry.

I don't see anything that specifically states what "all" encompasses. I was thinking it would be things like application, GFE, HUD maybe even the note. Anyone have any other information on what "all" means? Thank you.

We probably won't know what the identifier will look like until the Registry is ready.

As far as the definition of "all", I'm going to wait until they issue some guidance on that one.

Can the person who enters the bank information and the contact person be the same person? Our HR lady is going on maturity leave at the beginning of the year and in case the system is up and running as wondering if the person be the same.

Also, do we have to have a policy approved by October?

Okay, I'm really, really sorry...but I had to at "maturity leave"...Is this something we're supposed to get when our peers feel we have finally matured?????

I'm sorry as well, but I thought, does "maturity leave" equate to retirement?

I shouldn't cast stones though. I've frequently noted I type "the" instead of "they" & recently I spelled "want" as "what."

Oh, well. Pobody's nerfect!

I think you're on to something with "nerfect"....i see a Nerf slogan in the near future.

Yes, the System administrator and the POC can be the same person as long as they are not an MLO.



The rule becomes effectice 10/1/2010. Part of the rule requires that the bank have policies and proceudres. My assumption is that the P&P would be required by 10/1/2010. The rest will happen when the Registry is available.
We are going to have our P&P (at least bare bones) ready by 10/1/2010.

I know some people I would like to send on "maturity leave" just saying

Sorry, I had to LOL when I read that.

And I agree with Dani.

^^^^^^MOM!!!! He's talking about me AGAIN!


Oh...and I agree with Dani, too!

So...does anyone know exactly WHAT the correction was in the SAFE act version published in the FR Saturday for today?

What??? Do you have a link to this pronouncement? I didn't hear anything about this.

Here you go (this is the FRB's but they are all the same)

Now...if you figure out what the correction is...let us know!

Doesn't it say it's just a renumbering of the footnotes because they were numbered incorrectly? (This analysis provided after glancing for approximately 4 seconds, so maybe that's not it.)

I think this is all that changed - On pages 44656 through 44684, in Separate Part IV, footnotes 1 through 67 were not correctly numbered.