Has anyone out there considered whether a loan officer should NOT be considered for registration for the SAFE Act due to not being one of the "Best & Brightest"?

Lucy Griffin, on 7/12/2010, responded to a BOL question regarding SAFE Act training & testing for "bank loan officers" by stating:

"Loan officers that are employed by financial institutions (banks, thrifts and credit unions) must register, be fingerprinted and checked. The SAFE Act presumes that these institutional employers have adequate compliance programs and train their loan officers. In contrast, the Act assumes that mortgage loan originators that work in mortgage companies or independently have not been properly trained and monitored. therefore, the Act requires those folks to get trained and licensed."

Yes, most financial institutions have adequate compliance programs and train their loan officers. However, "not all loan officers are created equal" so to speak. Should a loan officer who requires more than periodic monitoring of residential mortgage transactions be allowed to represent a financial institution through SAFE Act registration and what, if any, compliance and reputation risk does a financial institution take when allowing loan officers known not to give their best effort to register?

A financial institution's management may believe that certain loan officers need additional training or "coaching", but operationally, all must be registered so as not to inconvenience loan customers.

Any thoughts?

I think the question is should this person ever have been allowed to represent the bank? Are they in the right job?