Is the following requirement referring to any arrangement we have with a third party related to mortgage loan origination, such as a secondary market setup, where we're the third party originator and the loans are table funded by the Investor, in which case we would need to ensure they have policies and procedures to comply with SAFE Act, or is it only referring to if we have third party mortgage loan originators who originate loans and send them to us?

Establish procedures designed to ensure that any third party with which the covered financial institution has arrangements related to mortgage loan origination has policies and procedures to comply with the S.A.F.E. Act, including appropriate licensing and/or registration of individuals acting as mortgage loan originators.

It's if they are referring to you. Think of it like a ladder. You have to ensure that anyone on a rung below you has P&P for SAFE Act compliance.