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#1549279 - 05/11/11 12:15 PM Annual Training
CUCO Offline
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Joined: Mar 2011
Posts: 40
Is there a requirement for annual training on the SAFE Act?

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S.A.F.E. Act Forum
#1549391 - 05/11/11 02:23 PM Re: Annual Training CUCO
Reads Regs Offline
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The regulation does not discuss a frequency of training. You would conduct the initial training prior to registering existing employees. You would also need to train any future new hires or existing employees who transfer into positions that meet the MLO definition and who will need to register. Section ___.104(b) states the following:

(b) Require that all employees of the bank who are mortgage loan originators be informed of the registration requirements of the S.A.F.E. Act and this subpart and be instructed on how to comply with such requirements and procedures;
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#1549664 - 05/11/11 07:13 PM Re: Annual Training Reads Regs
Orrsislander Offline
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So NO additional hours of training are required other than the initial training? How about subsequent annual training? If it's not mentioned then I assume there is none required!?

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#1549702 - 05/11/11 07:45 PM Re: Annual Training Orrsislander
#Just Jay Offline
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#Just Jay
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Cheeseheadland
If so, it will be a requirement at your state level.
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#1549781 - 05/11/11 09:06 PM Re: Annual Training Orrsislander
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My answer above related to entities subject to federal registration. If you work for a company that is subject to the state licensing requirements, then there are continuing education requirements. See these links. http://mortgage.nationwidelicensingsyste...ion%20Hours.pdf

http://mortgage.nationwidelicensingsystem.org/profreq/Pages/FAQ.aspx#education
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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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#1561390 - 06/07/11 02:46 PM Re: Annual Training Reads Regs
ruby2727 Offline
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Joined: Oct 2010
Posts: 5
Since we are an FDIC regulated bank, our employees are being registered, not licensed. We plan to train our employees about the requirements of registration, when to use their unique identifier, etc - is that what you mean by "initial training" for registered MLOs?

I just wanted to be sure you weren't referring to any additional training requirements prior to registering that I might have overlooked. Thanks!

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#1572182 - 06/30/11 02:47 PM Re: Annual Training ruby2727
EJB Offline
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Out west in credit union land
They're specific about renewals in the final rule published today:

3400.107 Minimum annual license renewal requirements. For an individual to be eligible to renew a loan originator license as required under 3400.103(f), a state must require the individual:
(a)(1) To continue to meet the minimum standards for license issuance provided in 3400.105; and
(2) To satisfy annual continuing education requirements, which must include at least 8 hours of education approved by the NMLSR. The 8 hours of annual continuing education must include at least:
(i) 3 hours of Federal law and regulations;
(ii) 2 hours of ethics (including instruction on fraud, consumer
protection, and fair lending issues); and
(iii) 2 hours of training related to lending standards for the nontraditional mortgage product marketplace.

Here is a link to the final rule. The information above is on page 34.

http://frwebgate1.access.gpo.gov/cgi-bin/PDFgate.cgi?WAISdocID=X8H6BV/0/2/0&WAISaction=retrieve
Last edited by EJB; 06/30/11 02:50 PM.
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#1572215 - 06/30/11 03:06 PM Re: Annual Training EJB
mtngrrl Offline
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Northern California
Originally Posted By: EJB
They're specific about renewals in the final rule published today:

3400.107 Minimum annual license renewal requirements. For an individual to be eligible to renew a loan originator license as required under 3400.103(f), a state must require the individual:


These are requirements for state-licensed originators, not for federally registered originators. FDIC banks don't have the education requirements, since our MLOs are just registered, not licensed.
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#1573620 - 07/05/11 02:48 PM Re: Annual Training mtngrrl
EJB Offline
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Posts: 41
Out west in credit union land
Thanks for pointing me in the right direction, mtngrrl. Sorry, anybody, for any undue heartburn!
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#1701610 - 05/21/12 03:46 PM Re: Annual Training EJB
Sci_Comply Offline
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Sci_Comply
Joined: Sep 2011
Posts: 189
Originally Posted By: EJB
They're specific about renewals in the final rule published today:

3400.107 Minimum annual license renewal requirements. For an individual to be eligible to renew a loan originator license as required under 3400.103(f), a state must require the individual:
(a)(1) To continue to meet the minimum standards for license issuance provided in 3400.105; and
(2) To satisfy annual continuing education requirements, which must include at least 8 hours of education approved by the NMLSR. The 8 hours of annual continuing education must include at least:
(i) 3 hours of Federal law and regulations;
(ii) 2 hours of ethics (including instruction on fraud, consumer
protection, and fair lending issues); and
(iii) 2 hours of training related to lending standards for the nontraditional mortgage product marketplace.

Can this continuing ed be in-house training? Do they have to be accredited continuing ed courses? We've been getting a lot of spam emails telling us about their training programs that will satisfy the 8 hours of continuing ed training. Just curious. Thank you!

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#1701925 - 05/22/12 01:25 PM Re: Annual Training CUCO
John Burnett Offline
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John Burnett
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Cape Cod
Sci -- Check out the date of the EJB post you have quoted, and note that the training requirements in the cited regulation applied only to state-licensed (not federally-supervised financial institution registered) MLOs.

Note also that those regulation are no longer the province of HUD; they have been ported over to the Bureau, where you'll find them at 12 CFR Part 1008. The Bureau, by the way, is considering imposing an annual "appropriate training" requirement on registered MLOs in connection with its implementation of TILA amendments made by the DFA.
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#1702345 - 05/23/12 02:09 PM Re: Annual Training CUCO
Always In Training Offline
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Posts: 1,110
Where the Green Grass Grows
we don't have any that are "state licensed" -- but I'm pretty sure that "must include at least 8 hours of education approved by the NMLSR" means exactly what it says.

If your institution already has a course or your training program vendor has a course that is approved by the NMLSR, then it would be okay -- otherwise, I think you are going to have to find someone else that would meet that standard.

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