The SAFE Act reqires us to ensure that any 3rd party with whom we have arrangements related to mortgage loan origination has policies/procedures for compliance. I'm interested in ideas for complying with this for mortgage brokers, purchased loans, builders, realtors, and home improvement contractors. Do we ask them to provide their unique identifier? How will we be able to verify it - has anyone seen information on how the public database will work? For loans purchased in bulk, do we just ask for their procedures? Thanks in advance...

I'm interested in this as well. I need to add this piece to my procedures.

Doesn't apply to us since we don't use brokers and we don't purchase, but here's my two cents...

I would get a list of their MLO id numbers and a copy of the employing entities policy and procedures, review them, and file in a due diligence file. Then annually I would ask for an updated list of MLO id numbers and a certification of any changes to their P&P. To verify the MLO ids, I would search the consumer database to ensure they are active. If your 3rd parties are non-banks you can do that now. If they are banks you will have to wait until after July to check it.

As far as how the database will work, I would assume it will work the same way it does now, but no one will know until it is actually up and running.