We are trying to get ready for the Safe Act requirements. I wondered if anyone else has decided what their process and procedures will be for Background Checks, Finger Printing, and
Registration requirements. Will this be handled through Human Resources or Compliance? I know that Compliance should make sure the procedures are followed and audit annually. Also, what will you do for fingerprinting? The options mentioned in a recent webinar were hiring an outside company, use a local law enforcement office, or actually ordering a kit to be used in HR. Any responses will be appreciated!

HR will be the system administrator and verifiy all the information after the loan officers enter it. Compliance will be the contact person in the Registry for the bank and will train and test for complaince.

As far as fingerprinting, CBCs, and credit reports, we are holding off on that because we don't know what the Registry will be doing. Currently, the registry (for non-bank MLOs) requires that the fingerprints be done through one of their vendors and the CBC is ordered from the FBI through the Registry. The BOL March webinar indicated that this practice will probably be the same for bank MLOs.

Also see this thread for lots of discussion:

http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1420636#Post1420636

Thanks so much for the information! It is really nice to know that we aren't behind the curve on this one!

We're still working on the details. Compliance will write policy, make sure everything is put into place, train and audit. Lending will identify those needed to register (with oversight from Compliance). HR will handle everything with the Registry. All of this subject to change, of course!

We'll make some of the other decisions once more is announced from/about the Registry and its' requirements.

If the bank already has fingerprints and did background checks on its mortgage loan officers, will these be required again? I'm understanding that if the fingerprints are less than three years old, those won't need to be done again, but what about background checks? I'm not seeing that specifically mentioned.
Thanks!