Answer:
There are no exceptions for any employee transactions. The bank is expected to have a standardized process to ensure compliance on every application.
First published on BankersOnline.com 12/17/12
SAFE Act: MLOs Initial Written Communication
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Question:
This question is in regards to the SAFE Act and disclosure of the MLO's unique identifier with the initial written communication. If loan is made to an employee of Sr. Management and the MLO is Sr. Management as well, does the requirement still apply? Obviously these employees know each other well, and since the unique identifier is a tool for customers to get info about the MLO would the disclosure of the unique identifier be relevant in this case? Would an examiner cite an Institution for not having disclosed the unique identifier on initial written communication?
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