Has anyone received any further information, or seen any classes, about the SAFE Act as it applies to employees of financial institutions?

Everything I'm seeing so far is geared to the more independant members of the mortgage industry in MN...

Thanks!

I just did a summary of this...PM me your e-mail address and I'll send it to you.

Only what's in the FDIC draft final rule & here on BOL. The MN law exempts LOs at depository institutions, so that's probably why you're not seeing anything geared towards them.

pacar, does your summary agree with MN Banker? My understanding is exempt if depository institutions.

Well, I just got something from HUD that says that "the SAFE Act mandates that all individual Mortgage Loan Originators (MLOs) either be licensed by the state where they do business or, if they are employed by a federally-regulated depository institution, be registered".

So, I'm thinking if we have a mortgage broker working in our office, we need to get her registered. And what about the lenders that do first lien mortgages in house on occasion? Do they need to register?

Ugh.

pacar, I sent you a message to get your summary. We've had examiners in here for the last few weeks and I got a little behind

I’m assuming your mortgage broker is an employee of the bank, correct? If so, they do need to be registered and would need to follow the guidelines in the FDIC draft final rule. HUD exempts financial institutions from their rule – theirs is geared toward non-bank originators. You need to be looking at the FDICs rule.

For your in-house lenders, if they do 5 or fewer loans in a 12 month period they are exempt; however keep in mind HELOCs are considered a residential mortgage loan under the definition. So even if they do very few 1st lien mortgages, I’m guessing they’ll still have to be registered based on the number of HELOCs that they do.

I’d highly recommend reading the FDIC’s draft final rule – that includes everything that will apply to you.

Good luck!

I'll read it more thoroughly...

I was just trying to figure out if I could exempt it from applying to us at all, so that I wouldn't spend that much time on something for no reason.

Thanks again...