We've decided to go with the workflow of the institution entering the MU4R. I am working on creating an excel for my lenders to complete and for some reason I have in my head that they have to give their last 10 years of employement history or do they have to give any Financial Services-Related Employment they have ever had?

In the regulation, at §___.103(d)(1)(ii), "Financial services-related employment history for the 10 years prior to the date of registration or renewal, including the date the employee became an employee of the bank;"

Thank you...I must have missed it when I was reviewing the regulation for it!

ooo.... Thanks, John! I entered my CO for a LOT longer than that! (like back to the 80's). I won't do that again. It was a PAIN!

I'm early in the process so not to the MU4R yet. Even by choosing "Workflow #2" can't you fill in as much of the form as you can and then send it to the MLO for them to fill any blanks before they attest? I'm hoping I don't have to try to come up with all their info myself.

I created an Excel spreadsheet that had the info from the MU4R fields plus a third column for the officers to enter their own information. They filled out the spreadsheet and sent it back to me. I used that to enter the MU4R info.

How many MLOs did you have to register, Cats?

We are a very!small! community bank with a grand total of 16 employees and 2 branches so we only had to register 2 of the 3 officers.

I have them fill out a MU4R information form, I'll process, they'll verify and authenticate.

Yes you can. That is what we are doing. There is a 'batch upload template' that you will want to use. It will ask minimal basic information; once you enter the information for your MLO's you can then upload it into the NMLS. We have about 200 MLO's to register and this is the best option for us. We have tested it and it works great.

Lori

We are doing that as well.

As a side note abotu employment history, we have seen a fair bit of consolidation in our area over the last few years, so we were curious on how MLOs should enter an employer when they have essentailly worked at the same place for say 12 years, but under 3 ownerships. This is the response we got back from the FDIC:

For the MLOs current employer (us) do we use our main address or the branch address where they work?

We used the branch address.

We planned to use the company's main address because we'd like the flexibility to move our branch MLOs to other branches (i.e. to fill in staffing deficiencies as needed, etc.). We interpreted branches to important only for state licensing. Does anyone see a problem with this practice?