S.A.F.E. Act _.104(i) "Establish procedures designed to ensure that any third party with which the bank has arrangements related to mortgage loan origination has policies and procedures to comply with the SAFE Act, including appropriate licensing and/or registration of individuals acting as mortgage loan originators."

Our procedures say that contracts with third parties will have a provision for attesting to their SAFE Act compliance.

1) Is that a reasonable way to comply with _.104(i)?
2) Does anyone have wording for that clause or attestation that they would share?

Thanks

You could include a step to look the entity up in the database.

Bump ...

Does anyone have any experience with this? How do others in the industry attemp to comply with this requirement?

Thanks,
Mike

You are on the only track there is...an attestation clause but you should have legal counsel draft one for your bank not borrow one from an unknown source. And in my opinion it would be foolish not to check the database which is freely available. How embarrassing to have your examiners check the database and find a problem you did not find.

OK, thanks.