SAFE ACT Responsibility????

Can anyone provide some insight as to how the SAFE Act Registration process is going to be handled at your bank? In other words, which Department(s) in your bank is being charged with the responsibility to ensure that everyone registers that needs to, who's going to monitor for required updates and annual renewals, and who (or what Department) is the overall "administrator" of the SAFE program?

Our bank will likely have about 400 employees who need to register. Is anyone planning on using a 3rd party vendor for this process?

I'm working on that same issue right now. I don't know how it will shake out at the end, but we'll definitely involve lending management, HR and compliance (that's me).

I'd like to hear how others are addressing the issue.

Isn't there suppose to be a worksheet for each employee that may be affected....will confirm or not whether they have to register? Maybe I'm getting my information crossed.

HR, Lending Area Supervisors and Compliance oversight.

Yes and no.
There is a form (MU4) that employees will submit in one form or another (online most likely). I called the NMLS yesterday and the answering rep stated that they are not sure if the form will be the same once the registry is ready for federally insured financial institutions.

We (audit) will be supplying the forms to employees to start completing and then once the registry is up and running they (employees) should be able to quickly submit the information that they have already filled out and collected on the form.

I passed the buck to the HR department. This seems like an HR issue to me and I got the board to buy off on that in the policy I wrote (and they approved).

Any idea when this will be taking effect?

No.
I called NMLS this week and they also do not know.
It is "assumed" that it will be ready by year end.

Tagging on here.
New URLA (Loan application) supposed to be used starting 7/1/10. The new part is the area for the LO to provide the Registry information that won't be available till maybe the end of the year. Anyone seen anything delaying the use of the URLA or do we run with it and not worry about the blanks until next year?

I have all the same questions. I am trying to catch up and get the policy/procedures written. I can't figure out how to get my people registered. Can't find the forms or anything. The loan officers that sell to the secondary market say that the lenders are requesting info on their certification. You would think they would know that nothing is ready yet.

In responding to an investor bulletin last week (requiring LO numbers on sold loans by 7/1/10), I contacted our FDIC compliance regulator. He seemed to the think the registration site was up. I don't see that- I think only the licensing site is up. Anyone have anything more on this?

Obviously, registration isn't mandatory yet but boy this is confusing.

And in answer to the thread above, we are driving this process in HR with sign off by compliance.

Same here. Lending and Compliance will identify existing employees that will need to be registered, HR will coordinate background checks, fingerprinting, training, etc. and maintain the records with their personnel file. Same for any new hires.

I was looking for the site yesterday and the bank registration is not up. Besides, without the final ruling I would be leary of registering my people.

I haven't thought yet about giving the maintence to HR. OUr HR is our COO and not easy to work with. I will have to run my procedures, when I get them written, by the Pres. and see what he has to say.

Anybody have any procedures they are willing to share?

You can't register your people yet.
Registration is not yet available to those working for a "federally insured financial institution."
I think we're all in that same blasted boat again!