"2. Retroactive obtaining of information not required. Section 1026.36(f)(3)(i) does not require the loan originator organization to obtain the covered information for an individual whom the loan originator organization hired as a loan originator before January 1, 2014, and screened under applicable statutory or regulatory background standards in effect at the time of hire. However, if the individual subsequently ceases to be employed as a loan originator by that loan originator organization, and later resumes employment as a loan originator by that loan originator organization (or any other loan originator organization), the loan originator organization is subject to the requirements of § 1026.36(f)(3)(i)."
So this means, if we screened the employee previously by pulling a criminal background check, regardless of whether it was for SAFE Act or not, we do not need to pull another criminal background check to satify the requirements of Reg Z for LOs, correct?
Last edited by leobsayer; 12/03/14 09:05 PM.