Who should own NMLS administration – HR or Compliance?

Answered by:

Question:

Who should manage the NMLS registration for our Mortgage Loan Originators (MLOs)? Is that an HR function, or should compliance do it?

Answer:

Neither the SAFE Act nor Reg Z prescribe who should perform the job, only that there be policies and procedures to manage and control it. Much depends on the size and complexity of your financial institution. Even if HR the primary overseer, compliance needs to be deeply involved with procedural development and monitoring. If compliance owns it all, audit must have a robust role to verify accuracy. At no time should compliance get involved in personnel matters, such as a deciding what to do about problematic records revealed by a criminal background check. So what should you do?

Tune into the upcoming webinar “Reg Z and SAFE Act Refresher: MLO / LO” on Wednesday, April 17, 2024 to learn more about how to best administer your compliance management program for these rules!

-----------------
Learn more about Rebekah Leonard's Reg Z and SAFE Act Refresher: MLO / LO webinar.