Once Loan Officer now HR Officer

Our current HR Officer just recently changed to this position. She was previously a loan officer and was/is registered with NMLS. Chief Credit Officer wants her to remain on our posted lobby list of MLO's in case she is ever needed to discuss loans with applicants. However, our procedures require the HR Officer to conduct annual SAFE account monitoring. I think we have a problem. If she is not permitted to discuss loans and her name is removed from any public listing, we should be ok for her to conduct the annual monitoring. Any comments?

If she is the NMLS administrator for your bank she cannot be a registered MLO.

Even if she will no longer be an active lender?

Yes, I was a registered MLO turned Compliance Officer, and because I was the administrator for the account I had to de-register myself. This was discovered through an external audit. I was also not an active lender.

This requirement for administrators is under 1007.103(e)(1)(I)(F)

(F) Name(s) and contact information of the individual(s) with authority to enter the information required by paragraphs (d)(1) and (e) of this section to the Registry and who may delegate this authority to other individuals. For the purpose of providing information required by paragraph (e) of this section, this individual and their delegates must not act as mortgage loan originators unless the covered financial institution has 10 or fewer full time or equivalent employees and is not a subsidiary; and

Discuss in the final rule is on page 44672, bottom of the 1st column. http://fedregistry.nationwidelicensingsystem.org/Resources/Final%20Rule.pdf