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Rich Moldenhauer
Flagship Bank Minnesota

 
 
Internal Training Class - Overview SAFE ACT
Contributed by:Compliance/BSA/Legal
Asset size: Bank with under $250m
Location: Midwest
Description: We wanted to document that we offer an "overview" of the SAFE ACT registration process and train new employees on the termonology. Most important was the understanding of "licensed" and "registered" because mortgage loan originators, who work for an insured depository or its owned or controlled subsidiary that is regulated by a federal banking agency, must be registered (not licensed). This is an overview from a bank perspective. I have it placed on our training web site to be assigned to new employees who fall within the guidelines of MLO. There are ten questions at the end of the summary. Answers are included.

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MORE PEER CONTRIBUTED DOCUMENTS:

35 Documents 7 Answers 13 Exam Watches 21 Vendor Reviews

Safe Act Policy
Asset size: with between $250m - $500m
Description: Safe Act Policy that is comprehensive, but still offers flexibility for you to develop procedures for the SAFE act.
SAFE Act Policy & Procedures
Asset size: with under $250m
Description: Standard SAFE Act Policy & Procedures tweaked for a Community Bank
Safe Act
Asset size: with under $250m
Description: Safe Act Policy


RELATED QUESTIONS AND ANSWERS:
Q
What requirements do you have on Documents impacted by SAFE Act?
Asked by: SVP,‚ Compliance/BSA/Legal
Asset size: Bank with
Location:NC

1.Denied or Withdrawn loans, Our denied/withdrawal activities are centralized and communication sent by an independent person, this person sends an adverse action document and include the MLO’s name. We started including the UIN number as well. What has your experience shown on handling this documentation? Should the Bank Information also be included on the adverse action?

2.We do not have any formal broker/referral agreements in place. However, many of our qualifying loans come from other Financial Institutions or “brokers”. Management has elected to use their applications for information and then have the applicant just complete certain sections of our application. Often times, the referring MLO UIN is not populated into the Application received; we have no evidence of that entity SAFE Act Policy & Procedures yet management elects to rely on their “completed” application to support our completed application. We appear to be walking a thin line here as to what we need to be requiring on their application as well as if we need their P&Ps. Our retail lenders work with many other FIs. Again there is no compensation paid to the “referring individual or entity.” What has your experience shown for handling this type of informal practices?

3.We have retail lenders who are also MLOs but acting as processor when assisting a Commercial Loan Officer. The Commercial Loan Officer is the originator yet the retail lender who is acting as a processor is signing and releasing their MLO information versus the loan originator in the communications. On the Commercial side, if a commercial loan officer uses an LOA, this “processor” never signs any documents only prepares and has the Loan Officer sign and includes all the MLO information. What has your experience shown with other clients on handling these types of situations?

4.What communications during the servicing of the loan do you include the Bank and/or MLO information? For example:

• Suspension of Open End Real Estate Loan
• Termination of Open End Real Estate Loan
• Insurance related communications on real estate related loans?
• Collection activities on real estate loans
A
Answered by:SVP, ‚ Compliance/BSA/Legal
Asset size: Bank with under $250m
Location: CA

#1 I agree with Nancy's comments on adverse action notices.

#2 We are a small co...
Q
Customer Education Program
Asked by: SVP,‚ Finance/Investments
Asset size: Bank with
Location:WA

Does anyone have a formal program or outline for customer education that you would be willing to share? This could be for product awareness, security tips, etc...
A
Answered by:
Asset size: Bank with
Location:

As an Account Manager at an IT firm I have helped set up educational programs for several...


RELATED EXAM EXPERIENCES:
NCUA - Compliance | September 2013
exam experience posted by a VP‚ Lending/Credit/Loan Admin from member with under $250m in assets
I was asked to show the documentation for our "Safe Act Audit". They wanted us to perform an internal audit. We were not prepared at all and had not done this audit. They also were very interested in seeing all of the materials, media channels, etc. on which you have the NMLS numbers posted.
FRB - S&S | October 2013
exam experience posted by a VP‚ Compliance/BSA/Legal from member with between $250m - $500m in assets
Wanted verification of SAFE Act training.
FDIC - Compliance | April 2012
exam experience posted by a VP‚ Lending/Credit/Loan Admin from member with under $250m in assets
none

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