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#1930162 - 06/06/14 02:01 PM Change personal information within 30 days
DoorKey Offline
100 Club
Joined: Nov 2002
Posts: 228
What steps are banks doing to ensure that MLOs are updating the Registry for changes to their personal information within 30 days of the change?

We send the MLOs an email reminder quarterly. However, emails can be easily ignored.
REMEMBER...Compliance is fun!

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S.A.F.E. Act Forum
#1930172 - 06/06/14 02:07 PM Re: Change personal information within 30 days DoorKey
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 77,573
Galveston, TX
What changes to their personal information?
The opinions expressed here should not be construed to be those of my employer:

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#1930173 - 06/06/14 02:08 PM Re: Change personal information within 30 days DoorKey
Matt_B Offline
Diamond Poster
Joined: Sep 2011
Posts: 1,648
A CU, Where Regs Don't Apply
All of ours signed a procedural statement when they were brought into the system, agreeing to update info within 30 days. I also do a quarterly audit of the system to make sure it matches us, and remind everyone come renewal time to make sure they check their info.

Audits generally find at least one problem, so people aren't always doing what they need to, but it's generally working at least.
Someone's about to get horned!

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#1930461 - 06/06/14 06:41 PM Re: Change personal information within 30 days DoorKey
NotDoneYet Offline
Gold Star
Joined: Jul 2010
Posts: 482
Our newly married MLOs have updated their information within that 30 day window. What about if they are transferred to another branch? Can that wait until the annual renewal?

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#2202369 - 01/08/19 08:52 PM Re: Change personal information within 30 days DoorKey
Half Pint Offline
Joined: Sep 2012
Posts: 75
Is this a SAFE Act requirement? Under which section in the regulation does it state MLO information is required to be updated within 30 days and the required information to be update? Thank you!

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#2202372 - 01/08/19 09:00 PM Re: Change personal information within 30 days DoorKey
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,585
From 1007.103(b):
"b) Maintaining registration. (1) A mortgage loan originator who is registered with the Registry pursuant to paragraph (a) of this section must:

(i) Except as provided in paragraph (b)(3) of this section, renew the registration during the annual renewal period, confirming the responses set forth in paragraphs (d)(1)(i) through (viii) of this section remain accurate and complete, and updating this information, as appropriate; and

(ii) Update the registration within 30 days of any of the following events:

(A) A change in the name of the registrant;

(B) The registrant ceases to be an employee of the covered financial institution; or

(C) The information required under paragraphs (d)(1)(iii) through (viii) of this section becomes inaccurate, incomplete, or out-of-date."

Found here:
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.

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