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Reg. Z & Reassessment of Loan Originator

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Regarding Reg. Z and reassessment of loan originator: Is it standard structure in a bank for the HR Team to own the reassessment process for loan originators under the SAFE Act?

The mortgage origination organization is required to reassess a mortgage loan originator only if the organization "knows of reliable information indicating that the individual loan originator likely no longer meets the required standards in § 1026.36(f)(3). For example, if the loan originator organization has knowledge of criminal conduct of its individual loan originator through a newspaper article, a previously obtained criminal background report, or the NMLSR, the loan originator organization must determine whether any resulting conviction, or any other information, causes the individual to fail to meet the standards in § 1026.36(f)(3)(ii), regardless of when the loan originator was hired or previously screened." Comment 36(f)(3)(ii)-3.

In such situations, it would be very common for the lender's HR team to be involved in the review of the record and any subsequent action, particularly if the HR team is involved in maintaining the organization's MLO registrations.

The HR team is also likely to have some involvement in the periodic training that's required under 1026.36(f)(3)(iii) to coordinate training and any evaluations involved.

First published on 08/23/2015

Last updated on Aug 24 2015

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