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#1451181 - 10/04/10 02:47 PM
Re: Final SAFE Act published today
mstark
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Joined: Nov 2005
Posts: 265
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We plan on registering our loan assitants just to be safe, because sometimes they do call the applicant to give them the terms the officer decides on and they sometimes take information such as financial, paystubs, etc.. Is anyone else doing this?
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#1451265 - 10/04/10 05:10 PM
Re: Final SAFE Act published today
Sugarbaker
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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We plan on registering our loan assitants just to be safe, because sometimes they do call the applicant to give them the terms the officer decides on and they sometimes take information such as financial, paystubs, etc.. Is anyone else doing this? Yes. We are registering all loan officers and loan assitants. The loan assistants are being registered because they not only may call and communicate the terms of the approved credit, but alos because our assistants produce and mail the GFE to the borrower.
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I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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#1451310 - 10/04/10 06:07 PM
Re: Final SAFE Act published today
Dani York, CRCM
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Joined: Nov 2005
Posts: 265
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Thanks Dani. Another questions: is anyone gathering information from MLO's now or are you waiting until the registry puts out a form to complete?
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#1451328 - 10/04/10 06:31 PM
Re: Final SAFE Act published today
Sugarbaker
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Joined: Jul 2002
Posts: 5,568
New Jersey
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We're waiting for the registry to provide more information. However, in the meantime, I printed the Form MU4 from the registry, to get an idea of what the input screen might look like. MU4 is the form that non-depository institution MLOs must complete to register.
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Management is doing things right; leadership is doing the right things. Peter Drucker
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#1451369 - 10/04/10 07:18 PM
Re: Final SAFE Act published today
Sinatra Fan
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Joined: Apr 2005
Posts: 3,663
TN
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We're waiting for the registry to provide more information. However, in the meantime, I printed the Form MU4 from the registry, to get an idea of what the input screen might look like. MU4 is the form that non-depository institution MLOs must complete to register. same here
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I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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#1451393 - 10/04/10 07:48 PM
Re: Final SAFE Act published today
Dani York, CRCM
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Joined: Nov 2001
Posts: 7,985
FINALLY ABOVE the gnat line
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I'm conducting training for all of our Consumer RE Lenders/assistants in November. Will provide each of them with the MU4 so they can begin gathering the information they will need to register. They will register themselves, but it helps to be prepared.
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My Opinion Only.
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#1451408 - 10/04/10 08:04 PM
Re: Final SAFE Act published today
waldensouth
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Joined: Nov 2005
Posts: 265
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Great information - thanks!
So we can let the MLO's register themselves? That will save our HR department, as our administrator, a lot of time.
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#1451554 - 10/05/10 01:34 PM
Re: Final SAFE Act published today
Clint,,,,,
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Joined: Nov 2005
Posts: 265
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Are these the forms that federally regulated banks are required to use?
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#1451614 - 10/05/10 02:17 PM
Re: Final SAFE Act published today
Sugarbaker
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Joined: Nov 2004
Posts: 2,309
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It looks like the NMLS will have new forms for the federal registration process. However, the documents they posted are not the forms themselves. They are documents that explain the field requirements for the data that needs to be completed on the forms. I think they are doing this to help the large banks that will want to register their MLOs using the batch process. This will help their IT people start to think about what they will need to program.
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.
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#1453394 - 10/08/10 01:51 PM
Re: Final SAFE Act published today
Reads Regs
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Joined: Jul 2002
Posts: 5,568
New Jersey
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I was reading through the Form MU4R, which outlines the information each MLO registrant must provide to the registry. Some of the information items seem a bit intrusive to me, and, I suspect, will seem the same to others: home phone number current residence address weight I'm so glad that I wrote our procedures to have the MLOs input their info into the registry. I could just see their reaction when our SAFE admiinstrator asks them "Your weight?"
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Management is doing things right; leadership is doing the right things. Peter Drucker
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#1455330 - 10/14/10 06:55 PM
Re: Final SAFE Act published today
Sinatra Fan
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Diamond Poster
Joined: Nov 2004
Posts: 2,309
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The NMLS website has been updated with information about two factor authentication that will be required for depository institutions accessing the federal registry. http://mortgage.nationwidelicensingsystem.org/fedreg/Pages/TwoFactor.aspx
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.
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#1455336 - 10/14/10 06:58 PM
Re: Final SAFE Act published today
Sinatra Fan
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10K Club
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#1457395 - 10/20/10 05:17 PM
Re: Final SAFE Act published today
ItsJustMe
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Joined: Nov 2008
Posts: 4,132
Somewhere in the middle
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Just want to clarify something for me:
Are the fingerprint requirements only when you hire someone or are registering a MLO for the first time, provided there are not fingerprints on file that are less than 3 yrs old?
It is not required every three years is it?
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I'm only responsible for what I say, not for what you understand.
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#1457519 - 10/20/10 07:03 PM
Re: Final SAFE Act published today
DD Regs
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100 Club
Joined: Dec 2009
Posts: 184
TX
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Do I have all/any of this correct?
Banks complete MU1R & Bank MLOs complete MU4R
The batch upload is the minimum required info and MU4R must still be completed. The batch upload is used as a base record.
Last edited by jross; 10/20/10 07:12 PM.
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#1457908 - 10/21/10 03:45 PM
Re: Final SAFE Act published today
Ninky
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Joined: Nov 2002
Posts: 20,656
The Swamp
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It would already be on your 1003, no?
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#1458005 - 10/21/10 05:33 PM
Re: Final SAFE Act published today
RR Joker
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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Not necessarily. We have the 1003 on our web site, where people can print and complete it. We will not print any MLO ID, because there is no way of knowing which--if any--MLO might receive the application.
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Management is doing things right; leadership is doing the right things. Peter Drucker
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#1458049 - 10/21/10 06:13 PM
Re: Final SAFE Act published today
Ninky
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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Is anyone including the unique identifier on the adverse action letter when a loan is denied before any disclosures or other written communication is provided? The way the reg reads is that a registered MLO shall provide their unique identifier to the consumer through the originator's initial written communication with a consumer, if any, on paper or electronically. We have a fast turnaround and do not send disclosures if a loan is declined before the 3 day disclosure window. The decline is from our institution, not the MLO. I believe the "if any" allows that there may not be written communication from the actual MLO.
Would appreciate opinions. Thank you. You are correct that the ID needs to be on the initial lwritten communication from the MLO to the applicant. We are putting the IDs on the MLOs business cards, in their signature lines on emails and letters, on earlies, and also next to their name on the AAN. Depending on the way you draft your AAns, will determine if you need to put their ID. Our AANs are drafted with the lloan officer's name on them, making it lkook like the MLO has sent the notice, so the ID would be required. If the AAN was drafted in a way where the MLO was not tied to it (say for instance signed by someone in loan operations who doesn't accept applications), you may be able to get away with not listing the ID. IMHO, it is probably safer to just include it and be done with it.
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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#1458334 - 10/22/10 12:49 PM
Re: Final SAFE Act published today
Ninky
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Joined: Nov 2005
Posts: 265
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Maybe this has been covered and I just missed it, but do we have to give the customer instruction on what the ID# is and how to access the registry or are we just assuming that every consumer is going to automatically know what the ID# is for?
I know that we have to be able to provide a list of all of our MLOs and their identifiers, but I don't recall the final rule giving details on explaining the process to the customer. Did I miss this somewhere?
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#1458338 - 10/22/10 01:00 PM
Re: Final SAFE Act published today
Sugarbaker
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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The rule requires the MLO ID to be given to the consumer. It does not require that you educate the consumer in what it is, what it means, which web site to access for more information, etc.
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Management is doing things right; leadership is doing the right things. Peter Drucker
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#1458459 - 10/22/10 03:06 PM
Re: Final SAFE Act published today
Sinatra Fan
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Gold Star
Joined: Nov 2005
Posts: 265
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Thanks Sinatra Fan. That is what I thought; just wanted to make sure I was on the right track.
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#1458999 - 10/25/10 03:52 PM
Re: Final SAFE Act published today
Ninky
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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Our adverse action notices are sent through our consumer lending system, not sent or signed by our individual MLOs. Also, we take our applications through a call center, so there is no 1003 or any other written communication on loans denied within 3 days, other than the adverse action letter. Are you saying the denials are automated and dispersed directly by the computer based on the information entered by the call center personnel? If so, you may be able to argue not including the ID. I, as a consumer however, would assume that the AAN came from the person who took my application unless the notice indicated otherwise. If it were me (and this is just my opinion and hypothetical since we don't have a call center), I would probably include an ID on the form, either by designating someone to be the AAN MLO, or by registering the people in my call center, depending on if they meet the 2 prong test.
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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