We have a handful of people registered. I am trying to determine just what we need to cover with them to satisfy the annual training requirement. Do you do this only for the registered people or everyone handling res. mortgage loan process?

What annual training requirement?

There is no annual training requirement. There is a requirement to ensure that the MLOs know their responsibilities, especially with regards the registration requirements.

However, it wouldn't hurt to restate that each year and include other loan participants so that they understand the requirements and don't inadvertently 'qualify' as MLOs.

Some materials I had specified an annual training component.

Good, thanks.

If there is an annual training requirement, it would be a state level requirement when they adopted SAFE, and not a federal requirement.

Review your state version of SAFE to be sure your state does not require more than the federal rules.

The sample procedures available through BOL indicate a training requirement for newly hired employees to be done within 90 days of employment.

Just to be sure...this is not specified anywhere in the Reg, right? It is just a sample procedure.

It was my understanding that the annual training requirements were limited to originators who work through lenders that are not insured depository institutions. In addition to the training requirements, they also had to pass state and national tests, which employees of insured institutions did not.

Has anyone heard of any impending changes to that?