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#2112874 - 01/03/17 06:59 PM Annual Audit required
Always In Training Offline
Diamond Poster
Joined: Jul 2006
Posts: 1,115
Where the Green Grass Grows
Is there a requirement to audit to ensure the information in the database for our MLO is still accurate on an annual basis?

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S.A.F.E. Act Forum
#2112892 - 01/03/17 08:01 PM Re: Annual Audit required Always In Training
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
Yes.

(f) Provide for independent testing for
compliance with this subpart to be
conducted at least annually by bank
personnel or by an outside party;
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2117874 - 02/10/17 07:25 PM Re: Annual Audit required Always In Training
Tessie Offline
100 Club
Joined: Jan 2006
Posts: 155
I have to start doing SAFE ACT audits and not sure exactly what I am doing. I have done some reading on Safe Act but a little confused on some issues. Do the MLO's have to have continuing education each year or just to get their MLO license?
Any tips on auditing would be greatly appreciated.

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#2117893 - 02/10/17 09:05 PM Re: Annual Audit required Always In Training
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
For your audit go to your regulator's Examination Manual and follow the exam procedures.

Whether the MLO will have to be licensed and take continuing education credits will be a matter of state law. In IN if the MLO works for an insured depository institution they do not have to be licensed or take continuing education credits.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2119613 - 02/27/17 04:22 PM Re: Annual Audit required Always In Training
fmissle Online
Diamond Poster
Joined: Jul 2007
Posts: 1,016
Pac NW
Agree with Dan. We have a thrid party complete our audit, but it's a very simple one compared with many others.

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#2120731 - 03/06/17 09:50 PM Re: Annual Audit required Always In Training
Bibliofiend Offline
100 Club
Joined: Feb 2006
Posts: 128
DuPage County, IL
Very topical. I just realized that it's time for our annual audit. I request our COO conduct it, based on the FDIC examination manual. (He has nothing to do with NMLS, so he's independent.) Even though our last audit was done by a third party, he's done the audit prior to that and we never had any issues. I'm sure that unless there are extreme issues, this is a low-priority item for the examiners.
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Top 10 reasons to procrastinate 1.

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